Manufacturing Resources International, Inc. v. John A. Squires, Under Secretary of Commerce for Intellectual Property and Director of the USPTO

Case Overview & Background

Parties and underlying dispute. Despite being captioned as a dispute against the USPTO Director, this is the appellate tail of an inter partes review (IPR) campaign arising from real patent litigation between an operating company and a global electronics giant. Manufacturing Resources International, Inc. (MRI) is an Atlanta-area, Georgia-based manufacturer of outdoor and semi-outdoor LCD digital signage displays, kiosks, and display thermal-management systems — a practicing operating company, not an NPE/PAE. In August 2022, MRI accused Samsung Electronics Co., Ltd. and [Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America) (together with Samsung SDS and integrators Coates Signco/Palmer Digital Group) of infringing five MRI display-cooling patents, filing a complaint with the International Trade Commission (Inv. No. 337-TA-1331) and a parallel suit in the Eastern District of Texas, MRI v. Samsung, No. 2:22-cv-00320 (E.D. Tex., filed 8/19/2022). The accused products were Samsung's outdoor "OHF" (and successor OHA/OHB) LCD signage lines — models such as OH46F/OH55F/OH75F/OH85F — whose thermal designs allegedly copied MRI's approach. The two patents at issue on appeal share a specification and are both titled "Constricted Convection Cooling System for an Electronic Display": U.S. Patent No. 8,854,595 ("'595," filed Mar. 26, 2009; issued Oct. 7, 2014) and its companion U.S. Patent No. 9,173,322 ("'322"). In one line, the claimed invention cools large displays — especially backlit LCDs exposed to direct sunlight — by placing a "constricted convection plate" immediately behind the display/backlight and using a fan to draw ambient air through the narrow channel thus formed, with the '595's dependent claim 8 adding "access apertures" in that plate. (Sources: RPX Litigation, Aug. 24, 2022; PTAB FWD IPR2023-00199, Paper 56; Korean trade-press reports; DocketAlarm IPR filings.)

Procedural posture and the appeal. Samsung answered the district-court/ITC assertions by petitioning the PTAB in late 2022 for IPRs on obviousness grounds based on prior-art references Kim (U.S. Patent No. 7,800,706), Na (Korean Pub. No. 10-2006-0016469), and others. The Board instituted IPR2023-00199 ('595, challenging claims 1, 4, 7, 8) and companion IPR2023-00220 ('322, challenging claims 1–5, 7–13, 16) in June 2023 before Judges Lee, Kokoski, and Hudalla, held a consolidated hearing on March 21, 2024, and issued Final Written Decisions in June 2024 holding all challenged claims unpatentable as obvious. MRI appealed to the Federal Circuit (No. 24-2228; companion appeal No. 24-2229 covers the '322 patent). Notably, Samsung — the real party in interest — withdrew from the appeal (the court revised the caption Sept. 24, 2024), leaving the USPTO Director as the appellee/intervenor defending the Board under 35 U.S.C. § 143; successive Directors Vidal, Brent, Stewart, and finally Squires appear in the caption as leadership changed. The venue matters because the Federal Circuit has exclusive appellate jurisdiction over PTAB IPR final written decisions (28 U.S.C. § 1295(a)(4)(A); 35 U.S.C. §§ 141(c), 319), reviewing Board fact findings for substantial evidence. After briefing (Dec. 2024–Mar. 2025) and oral argument (audio posted Mar. 6, 2026), a nonprecedential opinion authored by Judge Richard Taranto affirmed on March 31, 2026 (CAFC docket 24-2228; opinion PDF posted 3/31/2026). The panel (i) upheld as supported by substantial evidence the Board's finding that both Kim and Na disclose the claimed "constricted convection plate," crediting Samsung's expert over MRI's narrower reading; (ii) rejected MRI's proposed narrow construction of "access apertures" as lacking textual support; and (iii) upheld the Board's near-total discounting of MRI's objective indicia of non-obviousness. Applying Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366 (Fed. Cir. 2019), and In re Huang, 100 F.3d 135 (Fed. Cir. 1996), the court agreed MRI earned no nexus presumption because the allegedly successful Samsung products had unclaimed features (the displays themselves) beyond the claimed cooling system, and that MRI failed to prove copying via Samsung's teardown of an MRI display because substantial evidence (deposition testimony) showed Samsung's cooling design was completed before the teardown. (Sources: CAFC opinion 24-2228 (3/31/2026); Vitallaw/IP Law Daily case summary; CourtListener docket for companion No. 24-2224; Patterson Sheridan Fed. Cir. weekly summary, week ending Apr. 3, 2026.)

Why the case is notable. This is a textbook illustration of how a deep-pocketed accused infringer uses IPRs to neutralize a smaller U.S. competitor's core product patents: Samsung's three coordinated petitions (including IPR2023-00255, which also invalidated claims of related MRI patent 9,629,287) largely dismantled the MRI cooling portfolio that underpinned the E.D. Tex. and ITC enforcement campaign — reports from December 2023 indicate the ITC issued a no-violation determination, and the E.D. Tex. action appears to have closed. It also underscores the strategic reality that in IPR appeals where the petitioner declines to participate, the USPTO Solicitor's office defends the Board, and the patent owner faces the Director's counsel alone. Doctrinally, the affirmance is a useful data point on the strict nexus requirement for objective indicia: a patent owner cannot rest on "infringing product = coextensive product" assertions when the accused product embodies significant unclaimed features, and copying allegations fail where the accused product predates the alleged teardown. Market context matters too: outdoor digital signage is a growth market (projected to exceed $10B in the U.S. by 2027) in which Samsung is the global leader and MRI is a smaller U.S. innovator, making this a meaningful competitive-dispute precedent. Caveats: I could not independently verify the full panel membership beyond Judge Taranto's authorship (per Vitallaw), the final ITC determination's precise scope, or the disposition of the E.D. Tex. case, which are based on secondary reports (RPX, Yonhap, DCT docket aggregators); the underlying district-court judge and specific stay/termination order were not confirmed from PACER.

Important threshold note: the docket is an IPR appeal, not an infringement action

Before the chronology, a framing point: No. 24-2228 is not a patent infringement suit. It is MRI's direct appeal to the Federal Circuit from a PTAB inter partes review final written decision (35 U.S.C. §§ 141(c), 319), naming the USPTO Director as the appellee/intervenor. Accordingly, the classic infringement-litigation milestones you list — complaint/answer/counterclaims, Markman order, trial verdict, JMOL — do not exist in this docket. What exists instead is: (1) a parallel enforcement campaign by MRI (principally an ITC investigation, plus district-court cases) that triggered (2) Samsung's IPR petitions, which produced (3) the PTAB final written decisions, which MRI appealed here. I cover those in chronological order below, flagging where a "milestone" in your template has no analogue in an IPR appeal.

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1. Underlying enforcement context (the disputes that produced the IPRs)

Patents. MRI owns U.S. Patent No. 8,854,595 B2 ("Constricted Convection Cooling System for an Electronic Display," granted 2014-10-06) and its continuation U.S. Patent No. 9,173,322 B2 (the '322 patent). Both concern fan-driven cooling of electronic displays through a constricted convection channel. (PTAB hearing transcript; Unified Patents portal.)

ITC Investigation No. 337-TA-1331 ("Certain Outdoor and Semi-Outdoor Electronic Displays"). MRI asserted the '595 and '322 patents against Samsung and others at the ITC. The record reflects a notice of prior art dated 2023-01-04, a public hearing beginning 2023-06-26, and an ALJ determination that claims 1, 4, 7, and 8 of the '595 patent were invalid: claim 1 anticipated and/or obvious over Takeuchi, claim 1 anticipated by Kim, claims 4 and 7 obvious over Kim + Hong, and claim 8 obvious over Kim + Hong + Takahashi. Samsung's IPR expert (Robert Smith-Gillespie) had provided the same invalidity testimony in the ITC. (Petitioner's slide deck at the consolidated IPR oral hearing, 2024-03-21; Patexia exhibit listing for the IPR.)

District-court context. MRI has separately litigated the '595 patent family, e.g., Manufacturing Resources International, Inc. v. Civiq Smartscapes, LLC, No. 1:17-cv-00269 (D. Del.), and an earlier Civiq IPR on a related MRI patent (IPR2018-00774, institution denied 2018-09-25). Those cases are context, not the case at bar.

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2. The Samsung IPRs (PTAB)

Petitions filed. Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed:

• IPR2023-00199 challenging claims 1, 4, 7, and 8 of the '595 patent; and
• IPR2023-00220 challenging claims of the related '322 patent (a continuation of the '595 patent).

Real parties in interest identified by Samsung included Samsung SDS, Coates Signco, Coates US, and Industrial Enclosure Corp. d/b/a Palmer Digital Group. (PTAB Final Written Decision, IPR2023-00199.)

Institution. 2023-06-20 — the Board (Judges Jameson Lee, Jo-Anne M. Kokoski, and John A. Hudalla) instituted IPR2023-00199 as to all challenged claims and all grounds, after MRI's preliminary response. (Decision on Institution, Paper 9.)

PTAB trial phase. MRI filed a Patent Owner Response (sealed Papers 18/35; public version), Samsung a Reply (Papers 30/37), and MRI a Sur-reply (Paper 38). MRI relied on a declaration of Michael N. Gershowitz (Ex. 2006); Samsung relied on Robert Smith-Gillespie (Ex. 1002) and deposed Gershowitz (Ex. 1041). Samsung moved to strike MRI's Sur-reply exhibits 2055–2056 and 2058–2061 (Paper 44); MRI opposed (Paper 46).

Consolidated oral hearing. 2024-03-21 — the Board heard IPR2023-00199 and IPR2023-00220 together (Paper 53 transcript). Goodwin Procter argued for Samsung (Naomi Birbach, Sanjeet Dutta, Doug Kline, et al.); Kilpatrick Townsend & Stockton argued for MRI (John Alemanni, David A. Reed, et al.).

Final Written Decision. The Board issued its FWD in IPR2023-00199 in June 2024 (paper entered 2024-06-18; public redacted version posted 2024-07-03), determining all challenged claims (1, 4, 7, 8) of the '595 patent unpatentable and dismissing Samsung's motion to strike as moot. A parallel FWD issued in IPR2023-00220 on the '322 patent claims. (PTAB FWD; Docket Alarm filings.)

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3. Federal Circuit appeal (the case at bar: No. 24-2228)

Notice of appeal. MRI appealed the PTAB's '595 FWD (and the parallel '322 FWD) to the Federal Circuit under 35 U.S.C. § 141(c). Because the PTAB is not a party, the appellee is the USPTO Director — initially Kathi Vidal, later succeeded in the caption by John A. Squires, Under Secretary of Commerce for Intellectual Property and Director of the USPTO.

Panel and argument. The case was assigned to a panel including Judge Richard G. Taranto (per case metadata). Kilpatrick Townsend's David A. Reed argued for MRI; the USPTO Solicitor's Office (Robert McBride, et al.) argued for the Director — the same lineup that appeared in MRI's companion appeal.

Disposition. The Federal Circuit affirmed the Board's unpatentability determinations as to the '595 patent claims in a nonprecedential disposition; judgment entered and case terminated 2026-03-31. (Case metadata; cf. the mirror-image Rule 36 affirmance in MRI's related appeal No. 24-2300, entered 2026-04-15 by Judges Prost, Clevenger, and Stark.)

Post-judgment posture. In the related appeal (No. 24-2300, arising from IPR2023-00255 on MRI's '287 patent), MRI filed a combined petition for panel rehearing/rehearing en banc (circulated July 2026) arguing the Board violated the APA and In re Magnum Oil Tools / In re Nuvasive by adopting the petitioner's contentions without making its own findings. I found no public evidence of a similar rehearing petition in No. 24-2228 itself — but note the two appeals raise the same family of issues, and MRI's en banc petition in 24-2300 (filed after this case's affirmance) demonstrates the broader dispute remained active as of mid-2026.

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4. Effect of the IPRs on the parallel enforcement proceedings

• The ITC's invalidity findings on the same '595 claims (337-TA-1331) supplied the primary prior-art record (Takeuchi, Kim, Hong, Takahashi) that Samsung leveraged in the IPRs, and the PTAB reached the same result on the same claims.
• The IPR final written decisions, now affirmed on appeal, are estoppel-generating and effectively moot further infringement assertions of the invalidated '595/'322 claims in district court or the ITC against Samsung and the identified real parties in interest.
• The earlier Civiq IPR on a related MRI patent (IPR2018-00774, institution denied 2018-09-25) shows MRI's broader exposure to PTAB challenges across the cooling-display patent family, but it is not part of this appeal.

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Caveats on sourcing

• I could not retrieve the Federal Circuit's actual opinion/judgment text in No. 24-2228 (the affirmance appears to be a nonprecedential summary disposition; the specific date of any opinion is not confirmed beyond the 2026-03-31 termination date in the case metadata).
• Exact FWD entry dates for IPR2023-00220 and the precise filing date of MRI's notice of appeal were not separately confirmed in my search results.
• No docket entries for a Markman hearing, trial, verdict, JMOL, or fee motion exist because this is an IPR appeal, not an infringement action; if you intended a specific district-court or ITC case (e.g., 337-TA-1331 or the D. Del. case), I'd need the case number to develop that chronology.

Counsel of record — Manufacturing Resources International, Inc. (appellant)

Framing note: No. 24-2228 is not a patent infringement case; it is MRI's direct appeal from the PTAB's IPR2023-00199 final written decision, with the USPTO Director (John A. Squires) as the appellee/intervenor. MRI is the appellant (the functional "plaintiff-in-error"). Its counsel of record are the Kilpatrick Townsend & Stockton LLP attorneys who represented MRI in the underlying IPRs and on appeal. No separate local counsel appears in Federal Circuit practice.

Identified attorneys for MRI

1. David A. Reed — Lead appellate counsel (argued)

• Firm/location: Kilpatrick Townsend & Stockton LLP, Atlanta, GA.
• Role: Argued for MRI before the Federal Circuit.
• Experience note: Lead patent litigator at Kilpatrick Townsend with substantial PTAB/ITC and appellate IP practice; he argued the companion MRI appeals (Nos. 24-2224/24-2231 and the mirror-image appeal No. 24-2300) raising the same PTAB issues.
• Source: Companion Federal Circuit opinion in Manufacturing Resources International, Inc. v. Squires, Nos. 2024-2224, 2024-2231 (Fed. Cir. Apr. 7, 2026) ("DAVID A. REED, Kilpatrick Townsend & Stockton LLP, Atlanta, GA, argued for appellant"), available at cafc.uscourts.gov; vitallaw.com case digest for No. 24-2228 (noting the same argument lineup).

2. John C. Alemanni — Of counsel on the brief / lead PTAB attorney

• Firm/location: Kilpatrick Townsend & Stockton LLP, Raleigh, NC.
• Role: Of counsel on the Federal Circuit briefs (per the companion-opinion attorney listing: "John C. Alemanni, Carl Sanders, Raleigh, NC"); argued for MRI at the consolidated PTAB oral hearing in IPR2023-00199/-00220 on 2024-03-21.
• Experience note: Longtime Kilpatrick Townsend IP litigator who has represented MRI across its display-cooling patent enforcement campaign; vitallaw's digest of the 24-2228 disposition lists Alemanni as counsel for MRI.
• Sources: Fed. Cir. opinion Nos. 2024-2224/2024-2231 (attorney listing); vitallaw.com news digest, "Obviousness of convection cooling system for electronic displays affirmed" (Apr. 1, 2026) ("Attorneys: John C. Alemanni (Kilpatrick Townsend & Stockton LLP) for Manufacturing Resources International, Inc.").

3. Michael T. Morlock — Of counsel on the brief (Federal Circuit)

• Firm/location: Kilpatrick Townsend & Stockton LLP (office not confirmed; Atlanta-based practice group).
• Role: Listed as "also represented by" on MRI's Federal Circuit briefing.
• Experience note: Kilpatrick Townsend appellate/IP attorney; worked with Reed on the MRI-Federal Circuit appeals.
• Source: Attorney listing in the companion Fed. Cir. opinion, Nos. 2024-2224/2024-2231.

4. Carl Sanders — Of counsel on the brief (Federal Circuit)

• Firm/location: Kilpatrick Townsend & Stockton LLP, Raleigh, NC (per the companion opinion's "Raleigh, NC" office grouping).
• Role: Listed as "also represented by" on MRI's Federal Circuit briefing.
• Source: Attorney listing in the companion Fed. Cir. opinion, Nos. 2024-2224/2024-2231.

Caveats on sourcing

• I could not retrieve the full text of the 24-2228 disposition itself (2026 WL 879712, issued 2026-03-31); the attorney listing above for Morlock and Sanders comes from the companion MRI appeal (Nos. 2024-2224/2024-2231, decided Apr. 7, 2026), whose opinion states MRI "offers the same arguments that this court considered and rejected in Manufacturing Resources International, 2026 WL 879712" — strong evidence the same Kilpatrick Townsend team (Reed arguing; Alemanni, Morlock, Sanders on the brief) handled 24-2228, but that exact signature block for 24-2228 is not independently confirmed.
• Counsel for the appellee/Director in the 24-2228 digest is Fahd H. Patel, USPTO Office of the Solicitor (vitallaw digest); earlier USPTO Solicitor's Office personnel (e.g., Robert McBride) also appeared in the related appeals.
• No in-house counsel, local counsel, or pro hac vice entries were identified in public sources for the Federal Circuit docket.

Framing: there is no "infringement defendant" in No. 24-2228

As flagged in the earlier case sections, No. 24-2228 is not a patent infringement case. It is MRI's direct appeal under 35 U.S.C. § 141(c) from the PTAB's IPR final written decisions, in which the nominal appellee/intervenor is the USPTO Director (John A. Squires), not Samsung or any accused infringer. The relevant "defendant-side" counsel is therefore the U.S. Patent and Trademark Office's Office of the Solicitor in Alexandria, VA, which defends the Board's decision on behalf of the Director. Samsung — the IPR petitioner — is not a party in the Federal Circuit appeal; it withdrew from the appeal, leaving the Director to intervene and defend the Board's decision (VitalLaw, Obviousness of convection cooling system for electronic displays affirmed, Apr. 1, 2026).

Counsel for appellee/intervenor (Director John A. Squires)

Based on the best available sources (the companion Federal Circuit opinion in the same MRI/Squires appeal cluster, decided Apr. 7, 2026, and the VitalLaw case summary of this appeal):

• Fahd H. Patel — lead/arguing counsel; Office of the Solicitor, USPTO, Alexandria, VA.
  • VitalLaw's write-up of No. 24-2228 itself lists "Fahd H. Patel, U.S. Patent and Trademark Office, for John A. Squires." In the parallel MRI appeals (Nos. 24-2224/24-2231, decided Apr. 7, 2026), Patel "argued for intervenor." His portfolio is appellate defense of PTAB decisions in the Solicitor's Office.
• Nicholas Theodore (Nick) Matich IV — Solicitor, USPTO Office of the Solicitor, Alexandria, VA.
  • Listed as "also represented by" counsel for the Director in the companion MRI appeals (24-2224/24-2231 opinion, Manufacturing Resources Int'l v. Squires, 2026 WL ___, Fed. Cir. Apr. 7, 2026, slip op. at 2). Routinely appears in IPR appeals before the Federal Circuit.
• Robert J. McManus — Solicitor, USPTO Office of the Solicitor, Alexandria, VA.
  • Same "also represented by" listing in the companion MRI appeals; handles IPR-related appellate briefing for the USPTO.
• Michael Tyler — Solicitor, USPTO Office of the Solicitor, Alexandria, VA.
  • Same listing in the companion MRI appeals.

Caveat on the above three names: I could not retrieve the actual brief covers or docket entries for No. 24-2228 itself (the affirmance was nonprecedential — cited as Manufacturing Resources Int'l v. Squires, No. 2024-2228, 2026 WL 879712 (Fed. Cir. Mar. 31, 2026) — and no counsel listing appears in the summary disposition). The Matich/McManus/Tyler names are confirmed only for the companion MRI appeals (24-2224/24-2231), where the same Solicitor's Office team defended the same Director on the same patent family. Given the identical appellee and issue cluster, it is highly likely (but not independently confirmed) that they also appeared on the Director's brief in 24-2228.

Sourcing flag / discrepancy: The earlier-generated case summary states that "Robert McBride, et al." argued for the Director in this appeal. I found no confirmation of McBride in connection with No. 24-2228; the companion-opinion record shows Fahd H. Patel as the arguing solicitor for the Director, and VitalLaw likewise attributes Patel to this case. The McBride reference appears to be an error and should be disregarded unless a docket sheet shows otherwise.

For completeness — the adverse side

The appellant/patent owner is represented by Kilpatrick Townsend & Stockton LLP:

• John C. Alemanni — Kilpatrick Townsend, Raleigh, NC (VitalLaw lists him as the attorney for MRI in No. 24-2228; he was also PTAB lead counsel for MRI in the underlying IPRs).
• David A. Reed — Kilpatrick Townsend, Atlanta, GA (argued the companion MRI appeal before the Federal Circuit; per the earlier case summary he argued this appeal as well, though that is not independently confirmed).
• Michael T. Morlock — Kilpatrick Townsend, Atlanta, GA; and Carl Sanders — Kilpatrick Townsend, Raleigh, NC (both listed on the companion appeals' briefs; not confirmed on 24-2228's brief).

Key caveats

• The Director's counsel are government lawyers (USPTO Office of the Solicitor) — there is no private lead/local counsel, no in-house counsel, and no "local counsel" role in a Federal Circuit IPR appeal.
• I could not access the PACER/CM/ECF docket for No. 24-2228 directly, and the nonprecedential disposition does not publish a counsel list; the identity of the additional Solicitor's Office attorneys on the actual 24-2228 briefs is inferred from the companion appeals rather than directly verified.
• No infringement defendants, their counsel, or a district-court appearance list exists in this docket by design.