Manufacturing Resources International, Inc. v. U.S. International Trade Commission

Parties, accused technology, and patents. This appeal is the tail end of an ITC Section 337 enforcement campaign by Manufacturing Resources International, Inc. (MRI) — an Alpharetta, Georgia-based operating company that designs and builds outdoor and semi-outdoor liquid-crystal display (LCD) digital signage and kiosk products, not a patent-assertion entity. MRI asserted patents developed by its founder/inventor William Dunn covering thermal management for displays housed in sun-exposed outdoor enclosures. The appellate record (No. 24-1749) lists the ITC as appellee and [Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Samsung Electronics America, Samsung SDS America, Industrial Enclosures Corp. (d/b/a Palmer Digital Group), and Coates US Inc. as intervenors — the respondents from the underlying investigation. Although this matter's docket metadata identifies U.S. Patent No. 8,854,595 as the patent at issue, the underlying ITC complaint (Inv. No. 337-TA-1331, "Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof") asserted five related MRI patents: 8,854,595; 9,173,322; 9,629,287; 10,506,740; and 11,013,142. The '595 patent — "Constricted Convection Cooling System for an Electronic Display," filed March 26, 2009, and issued October 7, 2014 — claims a cooling system that draws outside air through a narrow "constricted convection channel" defined between a plate and the rear of the display, using fans to push/pull air uniformly across the posterior surface, optionally with a closed gas loop and refrigeration or thermoelectric conditioning (DocketAlarm PTAB exhibit copies of the patent and MRI's asserted claims 1, 4, 7–9). The accused products were imported outdoor/semi-outdoor electronic displays said to incorporate that cooling approach — including Samsung's outdoor signage (e.g., its OH-series displays and Samsung SDS products), Coates Signco's menu boards, and Palmer Digital Group kiosks (International Trade Today, Sept. 22, 2022).

Procedural posture and venue. The case is a Federal Circuit appeal from the U.S. International Trade Commission under 28 U.S.C. § 1295(a)(6), which vests the Federal Circuit with exclusive appellate jurisdiction over ITC Section 337 determinations — the venue matters because the ITC's only remedies are limited exclusion orders and cease-and-desist orders (no damages), conditioned on a complainant's showing of a domestic industry (§ 1337). The investigation was instituted September 19, 2022, and assigned to ITC Administrative Law Judge Monica Bhattacharyya (RPX Insight; EDIS records). The trajectory was decisive for MRI: the ALJ issued a Final Initial Determination of no violation on November 13, 2023; the Commission declined to review it and terminated the investigation on February 28, 2024; and the Commission denied MRI's petition for reconsideration on May 8, 2024. MRI then appealed (appeal docketed April 2024). On August 29, 2024, the Federal Circuit issued a nonprecedential order dismissing the appeal under Fed. R. App. P. 42(b) after the parties agreed to dismissal, with each side bearing its own costs and the mandate issuing the same day (Case 24-1749, Doc. 19; Justia; CAFC orders page). No merits determination was reached, and the specific judges on the dismissal order are not identified in the sources reviewed; the stipulated dismissal necessarily leaves the ITC's no-violation finding final and undisturbed.

Why the case is notable. First, the underlying ITC proceeding generated a Commission opinion (Sept. 11, 2023) on a live question of Section 337 procedure — whether the Commission may adjudicate infringement of unaccused "alternative" products and unasserted patent claims under the four-factor Certain Human Milk Oligosaccharides framework — with the Commission affirming ALJ Bhattacharyya's efficiency-driven approach over a partial dissent by Commissioner Stayin and a narrow concurrence by Commissioner Kearns (Fish & Richardson ITC Monthly Wrap-Up, Sept. 2023). Second, it reflects a recurring enforcement pattern: a U.S. manufacturer using the ITC's border remedies to press a thermal-management patent portfolio against large importers (Samsung, a Korean entity, and Coates Signco of Australia) in the fast-growing outdoor digital-signage market (e.g., stadium and out-of-home advertising deployments), with MRI simultaneously defending the same family in PTAB — Samsung filed IPR petitions referencing the '595/'322 family (IPR2023-00199, IPR2023-00220, IPR2023-00221 appear in PTAB exhibits), though the outcomes of those proceedings are not confirmed in the materials reviewed. Finally, the Rule 42(b) dismissal — no infringement finding, no exclusion order, no appellate precedent — means MRI obtained no relief after a full ITC merits defeat, underscoring the strategic risk of pursuing multi-patent Section 337 complaints through the Federal Circuit without a merits win. One caveat: the public record does not disclose the business terms or reasoning behind the joint stipulation of dismissal, so the settlement's substance is not verified here.

MRI v. ITC (Fed. Cir. No. 24-1749) — Key Legal Developments & Outcome

Important framing

The docketed case in the metadata — Manufacturing Resources International, Inc. v. U.S. ITC, No. 24-1749 (Fed. Cir., terminated 2024-08-29) — is not a standalone infringement suit. It is MRI's appeal of the ITC's no-violation determination in Inv. No. 337-TA-1331 (Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof). The substantive "patent infringement litigation" is that ITC § 337 investigation, with the Federal Circuit appeal as its last stage. The timeline below therefore tracks the ITC investigation (the merits forum), the appeal, and the closely-linked PTAB IPRs and district-court case. (Note: the underlying district-court case and several IPR appeal details are only partially confirmed by the sources I could retrieve; I flag those gaps rather than guess.)

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1. Filing & initial pleadings

2022-08-19 — ITC complaint filed. Manufacturing Resources International, Inc. (Alpharetta, GA) filed a § 337 complaint alleging infringement of U.S. Patent Nos. 8,854,595 (the '595 patent — the patent at issue in this appeal), 9,173,322, 9,629,287, 10,506,740, and 11,013,142 — all directed to "constricted convection" / closed-loop cooling for outdoor and semi-outdoor electronic displays — and requested a limited exclusion order and cease-and-desist orders. (Complaint; see ITC press release er0919ll1986; Federal Register Notice 2022-20607.)

Named respondents: Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung SDS Co., Ltd.; Samsung SDS America, Inc.; Coates Signco Pty Limited; Coates Visual LLC; and Industrial Enclosure Corporation d/b/a Palmer Digital Group. Accused products included Samsung's "OH Series," Coates' "ODMB" menu board, and Palmer kiosks. (International Trade Today, 2022-09-22.)

2022-09-19 — Institution. The Commission voted to institute Inv. No. 337-TA-1331; the matter was assigned to ALJ Monica Bhattacharyya. A target date was to be set within 45 days. (USITC press release; Federal Register Notice 2022-20607, published 2022-09-23.)

No "answers"/counterclaims in the ITC sense. Section 337 proceedings do not permit counterclaims; respondents defend via responses and motions practice. Notably, the respondents' camp also filed parallel offensive actions (see below).

Parallel district court filing — same day. MRI filed a mirror-image patent suit in the Eastern District of Texas against the Samsung entities on 2022-08-19, asserting the same five display-cooling patents against Samsung OH-series LCD signage models. (Korean trade press report of 2022-08-23 — The Guru; the IPR Final Written Decision in IPR2023-00199 confirms related district court litigation captioned "Manufacturing Resources, Inc. v. Samsung Electronics Co., No. 2:…" — the full case number was truncated in the source I retrieved and is not confirmed here.) The disposition of that E.D. Tex. action is not confirmed in the materials I retrieved.

Samsung counter-offensive at the ITC. Approximately three months after MRI's complaint, Samsung (with Samsung Electronics America, Samsung Research America, and Samsung International) filed its own § 337 complaint against MRI on 2022-11-05 alleging infringement of four LCD-panel/polarizer-related patents. (The Guru, 2022-11-09.) Whether that investigation was instituted and its outcome were not confirmed in the retrieved sources.

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2. Pre-trial motions of substance (ITC)

• Summary determination — economic prong of domestic industry. An Initial Determination granting summary determination that the economic prong of the domestic industry requirement was satisfied was issued in July 2023, and the Commission declined review on 2023-07-17. (USITC Commission Notices list.)
• Summary determination — non-infringement (respondents' motion, granted in part). An ID granting in part Respondents' Motion for Summary Determination of Non-Infringement was issued in mid-2023. The Commission twice extended the deadline to decide whether to review (2023-07-14, 2023-07-26, and 2023-08-15 notices), then on 2023-09-11 issued a Determination to review and, on review, affirmed the partial summary determination of non-infringement. (USITC Commission Notices; DocketAlarm PTAB exhibit showing MRI's later petition for review.) This narrowed the case before the evidentiary hearing — a strategically significant win for the respondents.
• No motion to stay pending IPR, motion to transfer, or motion to dismiss appears in the retrieved record for the ITC matter (such motions are atypical in § 337 practice); the parallel IPR petitions were filed while the ITC investigation was running (see § 7).

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3. Claim construction (Markman)

The ITC proceeding reached claim-construction stage. An "Updated Joint Claim Construction Statement" (filed in the investigation and later made an exhibit in IPR2023-00220, Ex. 2018) shows:

• Agreed constructions, including that the '595 patent claim 1 preamble is limiting, and § 112 ¶ 6 treatment of the "means for propelling gas…," "means for cooling the gas…," and "means for forcing air…" clauses with identified corresponding structures (refrigeration units, fans, conditioning units, etc.).
• Disputed terms submitted "for resolution in the Markman process," including "constricted convection plate," "constricted convection channel," "posterior display surface," "between," "side panels," and the fan-positioning language of '595 claims 1 and 4.

The ALJ's formal claim-construction order date was not in the retrieved sources, but the ID (Nov. 2023) necessarily applied those constructions — and MRI's later petition for review shows the ALJ's constructions of "posterior display surface" (as potentially spanning multiple/distinct surfaces and excluding edge-mounted light sources) were material to the invalidity findings on the '595 patent. (MRI Petition for Review of the ID, Public Version — filed with PTAB as Ex. 2055 in IPR2023-00220.)

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4. Discovery milestones

• The parties conducted full ITC discovery, with confidential materials later shared with the PTAB under a modified protective order in the related IPRs. (PTAB Order of 2023-12-11, IPR2023-00199 et al., noting parties' "additional discovery" agreement covering confidential ITC-produced documents and testimony.)
• Expert discovery included dueling technical declarations (later mirrored in the IPRs). (See PTAB records in IPR2023-00199.)
• 2023-06-26 — Evidentiary hearing convened remotely before ALJ Bhattacharyya (transcript of that date is in the IPR record as Ex. 2019 in IPR2023-00220), with MRI's CEO and CFO among the witnesses.

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5. Trial / merits determination and post-trial motions

2023-11-13 — Initial Determination on violation (no violation). The ALJ found no violation of § 337 — i.e., MRI failed to prove infringement/validity/domestic-industry elements as to the respondents for the asserted patents. Per MRI's later petition, the ID found the '595 and '322 patent claims invalid as obvious/anticipated over Kim and Takeuchi (among other references), in addition to non-infringement findings that had been narrowed by the earlier summary-determination rulings. (MRI Petition for Review of the ID; PatSnap/Eureka litigation summary: "Participant Disposition: No Violation Found.")

Late 2023 — MRI's petition for review of the ID was filed with the Commission (public version circulated as Ex. 2055 in the IPR proceeding). MRI argued, inter alia, that the ID erred on "constricted convection plate/channel," "posterior display surface," and "side panels," and that the ALJ abused discretion in applying Ground Rule 9.2 only against MRI. (Petition for Review, Public Version.)

2023-11-29 — Public-interest submissions were requested by the Commission (a standard step where remedies are contemplated, suggesting the Commission was still considering the remedial posture). (USITC Commission Notices.)

2024-02-28 — Commission final determination. The Commission declined to review the ID, adopted the no-violation finding, and terminated the investigation with no exclusion order or cease-and-desist order. (ITC Notice 337-1331, 2024-02-28; trade-press summaries of 2024-02-29.)

2024-05-08 — Reconsideration denied. The Commission denied MRI's petition for reconsideration and again declined to review the non-infringement determination. (ITC Notice of 2024-05-08; Chinese trade-remedy service translation, 2024-05-10.)

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6. Federal Circuit appeal and final disposition

Appeal docketed — Fed. Cir. No. 24-1749. MRI appealed the Commission's final no-violation determination. The appeal was active by late May 2024 (appellant and appellee docketing statements filed 2024-05-24; certified list transmitted 2024-06-05/06). (Patexia/Fed. Cir. docket for 24-1749.)

• 2024-05-29 — Intervention granted. Samsung Electronics Co., Samsung Electronics America, Samsung SDS America, Industrial Enclosures Corp. d/b/a Palmer Digital Group, and Coates US Inc. were granted leave to intervene as respondent-intervenors (Goodwin Procter counsel: Kevin P. Martin, Douglas J. Kline, Srikanth Reddy, Patrick J. McCarthy, Naomi L. Birbach, Gerard Cedrone, Darryl Woo). (Fed. Cir. Order, Doc. 14, 2024-05-29; Doc. 10 appearances.)
• 2024-06-28 — Briefing extension. The court granted MRI's motion extending its opening-brief deadline to 2024-10-04, warning "[n]o further extensions should be anticipated." (Doc. 17.)
• 2024-08-26 — Joint stipulation of dismissal. MRI, the ITC, and all intervenors filed a Joint Stipulation of Voluntary Dismissal under FRAP 42(b). (Doc. 18.)
• 2024-08-29 — Dismissal and mandate. The Federal Circuit voluntarily dismissed the appeal and issued the mandate; the order was nonprecedential. (Doc. 19; Patexia entry of 2024-09-01.)

Outcome: The appeal was dismissed with no merits determination and no relief awarded; the ITC's no-violation finding stands as the final result of the § 337 litigation. No settlement terms are of public record — the dismissal is consistent with, and likely driven by, the intervening PTAB invalidity rulings (below), which eliminated the asserted claims MRI would have needed to vindicate on appeal.

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7. Parallel PTAB IPR proceedings and their effect

Petitions. Samsung Electronics (with Samsung Electronics America) — joined in interest by Samsung SDS, Coates Signco/Coates US, and Palmer Digital Group — filed five related IPRs against MRI in late 2022/early 2023 challenging all five asserted patents:

(Sources: PTAB papers — IPR2023-00199 Final Written Decision; docketalarm.com copies of IPR2023-00199/-00220 papers; POA of 2022-11-20.)

Institution. The Board instituted IPR2023-00199 on 2023-06-20 on all challenged claims and grounds (Takeuchi; Kim alone and with Hong/Takahashi; Na in combination), rejecting MRI's preliminary-response arguments. The other four IPRs were instituted around the same time (June 2023).

Effect on the ITC case. The IPRs ran in parallel with the ITC investigation and appeal, creating a coordinated two-front attack: the respondents used the IPR record (including ITC confidential discovery) while the ITC merits phase proceeded, and the PTAB heard oral argument in March 2024 — after the Commission's Feb. 2024 termination but before MRI's appeal brief was due.

Final Written Decisions (June 2024). For IPR2023-00199 ('595 patent), the Board issued a Final Written Decision on June 18, 2024, determining all challenged claims (1, 4, 7, and 8) unpatentable under a preponderance standard, and dismissing as moot Samsung's motion to strike. (IPR2023-00199 FWD, entered 2024-06-18; joint proposed redactions filed 2024-07-03.) The companion decisions on the '322, '142, '740, and '287 patents issued in the same June 2024 window (the retrieved sources directly confirm the '595 decision; the others are corroborated by the parties' joint handling of the decisions and later reporting).

Effect on the appeal and disposition. The mid-2024 PTAB invalidation of the very claims MRI asserted in the ITC case made the Federal Circuit appeal of the ITC's no-violation finding untenable — explaining the joint stipulation of dismissal filed 2024-08-26 and the dismissal order of 2024-08-29. The IPRs therefore functionally mooted the ITC appeal.

Post-dismissal appellate stage (not part of 24-1749). MRI separately appealed the PTAB Final Written Decisions to the Federal Circuit. According to Korean trade-press reporting (KPI News, 2026-04-01), the Federal Circuit affirmed the PTAB's obviousness/invalidity rulings against MRI on 2026-03-31 as to MRI's core cooling patents (specifically the '595 and '322 patents), rejecting MRI's commercial-success secondary-considerations arguments and confirming Samsung's independent design. I could not verify the appeal docket numbers or opinion text from primary sources in the materials retrieved, so treat that 2026 affirmance as reported-but-unverified.

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Bottom line

• The § 337 litigation (the underlying merits dispute) ended with a complete MRI loss at the ITC: partial summary determination of non-infringement affirmed (2023-09-11), no-violation ID (2023-11-13), Commission termination without remedies (2024-02-28), and denial of reconsideration (2024-05-08).
• The Federal Circuit appeal (24-1749) was voluntarily dismissed by joint stipulation on 2024-08-29 with mandate issuing the same day — no merits ruling, no relief — after the PTAB's June 2024 Final Written Decisions invalidated the '595 claims (and companion patents).
• The parallel district court action in E.D. Tex. and Samsung's separate ITC complaint against MRI are part of the broader dispute, but their docket numbers and dispositions were not confirmed from the sources available to me and are not necessary to the disposition of 24-1749.

Sourcing caveat: Dates and events above are grounded in the ITC Federal Register notices and press releases, the USITC Commission Notices index, the Federal Circuit docket (via Patexia), and PTAB papers (via DocketAlarm). Counsel names are from the Fed. Cir. docket entries and PTAB papers. The E.D. Tex. case number, the status of Samsung's counter-ITC investigation, the individual FWD dates for IPRs 2023-00220/00221/00254/00255, and the specifics of the 2026 CAFC affirmance are the points I could not fully verify and should be confirmed against PACER, EDIS, and USPTO PRPS before being relied on in a filing.

Answer

Threshold clarification

The "case" in your metadata (No. 24-1749) is not a district-court patent infringement suit. It is MRI's Federal Circuit appeal of the ITC's no-violation determination in Inv. No. 337-TA-1331 (Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof). The appeal was voluntarily dismissed under Fed. R. App. P. 42(b) by order of Aug. 29, 2024 (Doc. 19), with each side bearing its own costs and no merits decision (cafc.uscourts.gov order PDF; Justia copy of Doc. 19). No appellate briefing on the merits occurred.

Important sourcing caveat

I was able to verify MRI's trial counsel in the underlying ITC investigation from primary ITC record documents, but I could not retrieve the Federal Circuit CM/ECF docket (entries 1–18 preceding the dismissal order, which would include the notice-of-appearance forms naming counsel of record on the appeal). The filings are not sealed, but I found no publicly indexed docket sheet, Law360 piece, or PACER summary listing the appellate entry-of-appearance counsel. Consequently, the attorneys below are confirmed as MRI's counsel in the ITC investigation from which the appeal arose — and the same firm that would have handled the appeal — but I cannot state with certainty who formally appeared on the CAFC docket.

Confirmed counsel for MRI in the underlying ITC investigation (337-TA-1331)

MRI was represented throughout the ITC investigation by Kilpatrick Townsend & Stockton LLP. The public evidentiary hearing transcript (Vol. I, June 26, 2023) lists these Kilpatrick Townsend attorneys appearing for MRI, and IPR record exhibits (e.g., IPR2023-00220 Exhibit 2018) confirm the firm's role, with Aarti Shah as the signing/signatory counsel:

The ITC litigation email address used in filings was MRI-Samsung@kilpatricktownsend.com, and the firm's signature block appears on MRI's ITC claim-construction statements (DocketAlarm copies of IPR exhibits).

On appeal (24-1749)

• I found no verifiable public source identifying the specific attorneys who entered appearances for MRI in the Federal Circuit. Because the case was dismissed ~4 months after filing without briefing, the CAFC docket likely contains only ministerial filings (docketing statement, certificate of interest, entry of appearance, and the joint stipulation of dismissal). If you need the definitive appellate counsel of record, the authoritative source is the CAFC docket sheet for 24-1749 on PACER (or the CAFC's public CM/ECF query), which lists the filing attorneys on the entry-of-appearance and dismissal documents.
• In-house counsel: No MRI in-house attorney is identified in any source I located.
• Intervenors/respondents on the appeal were Samsung entities, Palmer Digital Group, and Coates US Inc., represented at the ITC by Goodwin Procter LLP (Douglas J. Kline, Srikanth K. Reddy, Christie Larochelle, Harrison Gunn, Kara Grogan — Boston; Naomi L. Birbach, Christine Potkay, Christina Denise Go — New York) per the IPR exhibit. The ITC itself was represented by its Office of the General Counsel.

Bottom line: The only well-sourced counsel for MRI are the Kilpatrick Townsend attorneys listed above from the ITC investigation, with Aarti Shah as the lead; the formal counsel-of-record list on the Federal Circuit docket could not be confirmed from available public sources and should be verified against the CAFC docket before relying on it.

Based on the Federal Circuit docket for Manufacturing Resources International, Inc. v. International Trade Commission, No. 24-1749 (Fed. Cir.), the only appellee (the "defendant" side in this appeal) is the U.S. International Trade Commission. The ITC's Office of the General Counsel represents the agency in Section 337 appeals.

Counsel of Record for Appellee (U.S. International Trade Commission)

Per Docket Entry No. 2 (filed May 6, 2024) — "Entry of Appearance for Paul D. Lall; Wayne W. Herrington as counsel for Appellee ITC" — and Docket Entry No. 8 (May 24, 2024, Docketing Statement for Appellee ITC, filed by Paul Lall):

1. Paul D. Lall

• Role: Government counsel (lead counsel for the appellee ITC; signatory on the ITC's docketing statement)
• Firm/office: Office of the General Counsel, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436 (contact listed in Federal Register notices as tel. (202) 205-2043)
• Experience note: A Commission attorney who routinely handles ITC Section 337 matters and agency regulatory work; his name appears on Commission Federal Register notices in his OGC capacity.

2. Wayne W. Herrington

• Role: Government counsel for the appellee ITC (appeared via Docket Entry No. 2)
• Firm/office: Presumed Office of the General Counsel, U.S. International Trade Commission, Washington, DC — though I could not independently confirm his current OGC title from publicly available sources, his sole appearance in this appeal was on behalf of the ITC.
• Experience note: Has been associated with ITC Section 337 investigative work in Commission publications (including prior ITC opinion/notice materials); specific prior Federal Circuit argument history is not well documented in sources I retrieved.

Additional context

• Appellant (MRI) counsel (not the defendant): Kilpatrick Townsend attorneys Mitchell G. Stockwell, Russell A. Korn, David A. Reed, Dario A. Machleidt, Alton L. Absher III, and Matthew J. Meyer entered appearances (Dkt. Nos. 3, 7).
• Intervenors (Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung SDS America, Inc.; Industrial Enclosures Corp. d/b/a Palmer Digital Group; Coates US Inc.) — who were the actual respondents in the underlying ITC Investigation No. 337-TA-1331 — were represented by Goodwin Procter attorneys Kevin P. Martin, Douglas J. Kline, Srikanth Reddy, Patrick J. McCarthy, Naomi L. Birbach, Gerard Cedrone, and Darryl Woo (Dkt. No. 10).
• Procedural posture caveat: Because the appeal was voluntarily dismissed under Fed. R. App. P. 42(b) on August 29, 2024 (Dkt. No. 19; mandate issued same day), the ITC's counsel never filed a merits brief. Their substantive appellate work in this matter was limited to appearances, the docketing statement, and the joint stipulation of dismissal (Dkt. No. 18, filed Aug. 26, 2024).

Sources: Patexia docket listing for No. 24-1749 (Dkt. Nos. 2, 8, 10, 18, 19); Federal Register notice listing Paul Lall, Office of the General Counsel, USITC; Federal Circuit order of Aug. 29, 2024 (Justia/CAFC). No filings in this appeal were sealed, and both listed ITC attorneys made timely appearances.