Samsung Electronics Co., Ltd. et al. v. Manufacturing Resources International, Inc.

Case Overview & Background

The parties and the technology. This matter is a defensive inter partes review brought by Samsung Electronics Co., Ltd. and [Samsung Electronics America, Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) (collectively, "Petitioner"/"Samsung") against Manufacturing Resources International, Inc. ("MRI"), the patent owner — not a classic NPE/PAE dispute. MRI is an operating company: an Alpharetta, Georgia-based manufacturer of commercial outdoor and semi-outdoor digital LCD displays, founded around the work of inventor William R. Dunn, who holds a large portfolio of display-cooling patents (Korea Times describes MRI as an "Atlanta-based manufacturer of outdoor and semi-outdoor digital liquid-crystal displays"; MRI's own PTAB filing describes itself as a long-time display maker with "hundreds of U.S. and foreign patents" — Paper 7, IPR2023-00199). Samsung is the world-scale electronics and digital-signage vendor. The accused products are Samsung outdoor and semi-outdoor electronic displays/signage products (e.g., displays used in outdoor kiosks and digital signage), which MRI alleged incorporate its patented cooling designs; MRI also alleged induced infringement through Samsung's user manuals and online instructions encouraging customers to use the displays in infringing ways (UniCourt summary of Complaint, 2:22-cv-00320). MRI asserted five patents in the underlying enforcement campaign, including the patent at issue here, U.S. Patent No. 8,854,595 B2 ("'595 patent," "Constricted Convection Cooling System for an Electronic Display," filed Mar. 26, 2009; issued Oct. 7, 2014), which is directed to cooling an electronic display by placing a "constricted convection plate" behind the display's posterior surface and using side panels to define a narrow "constricted convection channel" (with an entrance and exit) through which a fan draws outside air — i.e., constricted-channel airflow to cool the rear of the display (claim 1; CAFC opinion, MRI v. Squires, No. 24-2228, slip op. at 3–4). The related asserted patents (9,173,322; 9,629,287; 10,506,740; 11,013,142) cover adjacent MRI display-cooling and closed-loop/open-loop airflow technology (Unified Patents docket, 2:22-cv-00320).

Procedural posture. The record case (IPR2023-00199, PTAB) is the administrative validity challenge, but it sits inside a broader infringement fight. On August 19, 2022, MRI sued Samsung Electronics Co., Samsung Electronics America, Samsung SDS Co., and Samsung SDS America in the Eastern District of Texas (No. 2:22-cv-00320), assigned to Chief Judge Rodney Gilstrap with referral to Magistrate Judge Roy S. Payne — a venue historically favored by patent plaintiffs (RPX Insight; UniCourt). The same day, MRI filed an ITC Section 337 complaint (Investigation No. 337-TA-1331, "Certain Outdoor and Semi-Outdoor Electronic Displays"), naming the Samsung entities plus Coates Signco/Coates Visual and Industrial Enclosure Corp. d/b/a Palmer Digital Group (Samsung's sign-integration partners, later listed as real parties-in-interest in the IPR) and seeking limited exclusion and cease-and-desist orders (RPX, Aug. 24, 2022; FWD Paper 56, IPR2023-00199, § I.A.). Samsung answered in kind at the PTAB: it filed the IPR petition on November 22, 2022, the Board (Judges Lee, Kokoski, and Hudalla) instituted review on June 20, 2023 as to all challenged claims (1, 4, 7, 8) and all grounds, and after a consolidated hearing with the related IPR on the '322 patent (IPR2023-00220), the Board issued its Final Written Decision on June 18, 2024, holding all challenged claims unpatentable as obvious over combinations of prior art such as Kim (U.S. 7,800,706), Na (Korean Pub. 10-2006-0016469), Takeuchi, Hong, and Takahashi (FWD, IPR2023-00199, Paper 56). MRI appealed to the Federal Circuit (MRI v. Squires, No. 24-2228), which affirmed in a nonprecedential opinion dated March 31, 2026 (cafc.uscourts.gov, No. 24-2228). Meanwhile, MRI's ITC bid failed: the ALJ issued a Final Initial Determination of no violation (Nov. 13, 2023), the Commission declined review (Feb. 28, 2024) and denied reconsideration (May 8, 2024), and MRI's Federal Circuit appeal (No. 24-1749) was voluntarily dismissed in August 2024. Note: the docket-level disposition of the E.D. Tex. case (2:22-cv-00320) — e.g., whether it was stayed, consolidated, or resolved by settlement — was not clearly established in the sources I found; RPX shows its last docket entry around March 2024, and I could not verify its final outcome, so that specific fact should be treated as unconfirmed.

Why the case is notable. This is a "parallel-track" enforcement story: a domestic display manufacturer with a genuine product business (and a prior Delaware enforcement against Civiq Smartscapes over the same '595 patent) took on Samsung simultaneously in the ITC, East Texas, and now through multiple Samsung-initiated IPRs (IPR2023-00199, -00220, -00221, -00254, -00255) targeting its cooling-patent family. The outcome is a clean sweep for Samsung on validity and non-infringement — the PTAB invalidated every challenged '595 claim on obviousness (with the Federal Circuit affirming), and the ITC found no violation — illustrating how a coordinated IPR-plus-ITC defense can unravel a display-technology assertion campaign. For the outdoor/semi-outdoor digital-signage market, the case matters because it tests how far patent protection extends over a foundational thermal-management approach (narrow-gap "constricted convection" cooling behind LCD panels) in a segment where Samsung, MRI, and other vendors compete for kiosk, transit, and out-of-home display business. One caution: several descriptive facts about MRI (its market position and "hundreds of patents") come from MRI's own pleadings and secondary press accounts rather than an independent judicial finding, and the specific Samsung product model numbers accused were not itemized in the sources I reviewed.

Key Legal Developments & Outcome — MRI v. Samsung (E.D. Tex. 2:22-cv-00320) and the Parallel Administrative Track

A caution up front: my searches recovered detailed public records for the ITC investigation (337-TA-1331) and the PTAB IPRs, but only fragmentary records for the district court docket (E.D. Tex. 2:22-cv-00320), which is PACER-restricted. Specific district-court motion practice, answers, and claim-construction rulings could not be independently verified, and I flag those gaps below rather than fabricate entries.

I. Chronology

A. District court filing (E.D. Tex.)

• 2022-08-19 — MRI filed its complaint in Manufacturing Resources International, Inc. v. Samsung Electronics Co., Ltd. et al., No. 2:22-cv-00320 (E.D. Tex.), assigned to Chief Judge Rodney Gilstrap with referral to Magistrate Judge Roy S. Payne. Named defendants: Samsung Electronics Co., Samsung Electronics America, Samsung SDS Co., and Samsung SDS America. The complaint asserted the same five display-cooling patents later asserted at the ITC (U.S. Patent Nos. 8,854,595; 9,173,322; 9,629,287; 10,506,740; 11,013,142), each with claim charts attached; MRI demanded a jury trial (Unified Patents litigation portal, docket entry of 2022-08-19; RPX Insight, docket 2:22-cv-00320; UniCourt).
• Answer/counterclaims: Not verified. No reliable public source located for Samsung's answer, any counterclaims, or MRI's reply. RPX and Ex Parte list the case as "Closed" with a last docket entry of 2024-03-12 and ~653 days in litigation — but the dispositive order (stipulated dismissal, judgment, or dismissal for forum/estoppel reasons) is not confirmed from my sources. The status must be treated as unverified detail, as flagged in the prior case overview.

B. Parallel ITC investigation — the forum where substantive merits were actually litigated (Inv. No. 337-TA-1331)

• 2022-08-19 — MRI filed a parallel Section 337 complaint with the ITC against the Samsung entities, Coates Signco/Coates Visual, and Industrial Enclosure d/b/a Palmer Digital Group (RPX, Aug. 24, 2022; USITC Notice of May 8, 2024, at 2).
• 2022-09-23 — Commission instituted Investigation No. 337-TA-1331 ("Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof"), 87 Fed. Reg. 58132–33; assigned to ALJ Monica Bhattacharyya (RPX; USITC May 8, 2024 Notice at 2). The Commission's Office of Unfair Import Investigations did not participate.
• 2022-10-24 / 2022-11-10 — Order No. 6 terminated Coates Visual and substituted Coates US Inc.; Commission declined review (Nov. 10, 2022) (USITC May 8, 2024 Notice at 2).
• 2023-01-25 through 2023-03-08 — Claim construction (Markman). Under Order No. 7, the parties filed a joint claim-construction chart (Jan. 25, 2023), opening briefs (Feb. 1–2, 2023), rebuttal briefs (Feb. 15, 2023), and held a Markman hearing on March 1, 2023, followed by an updated joint chart (Mar. 8, 2023). The parties relied on, and the order addressed, constructions from MRI's prior Delaware case, MRI v. Civiq Smartscapes, No. 17-269 (D. Del. Mem. Op. Sept. 27, 2018), which had construed terms of the '595, '322, and '287 patents. The ITC's substantive claim-construction order issued around May 15, 2023 (ITC Order, EDIS, attached as Ex. 1034 in IPR2023-00199, dated May 15, 2023).
• 2023-05-04 / 2023-06-05 — Order Nos. 10–11 terminated Samsung SDS Co. Ltd. and Coates Signco Pty Ltd. as respondents (Commission notice June 5, 2023); Samsung SDS America and the remaining respondents proceeded to hearing (USITC May 8, 2024 Notice at 2).
• 2023-04-27 — Respondents moved for summary determination of non-infringement as to groups of products (Mot. Dkt. No. 1331-008, EDIS Doc. ID 795633); MRI opposed (Fisher Phillips/Fish & Richardson public filing of MRI's response).
• 2023-06-15 / 2023-07-17 — Order No. 19 granted summary determination that MRI satisfied the economic prong of the domestic industry requirement; Commission declined review (July 17, 2023).
• 2023-06-20 / 2023-09-11 — Order No. 21 granted-in-part summary determination of non-infringement as to certain unaccused products (OH24B, OM46B/OM46N, OM55B/OM55N, OM75A); Commission affirmed on Sept. 11, 2023 (USITC May 8, 2024 Notice at 2–3).
• 2023-11-13 — ALJ issued the Final Initial Determination (FID) finding NO violation of Section 337. The FID found no infringement of the remaining asserted claims (claim 12 of the '287 patent; claims 1, 4, 7, 8, 9 of the '595 patent; claims 3–5, 8, 9, 12, 13 of the '322 patent; claims 1, 5 of the '740 patent; claims 6, 10 of the '142 patent) and additionally found the '595 and '322 patents' asserted claims invalid as obvious over prior art including Kim and Takeuchi. The FID also adjudicated Samsung's redesigned OH46B/OH55A products as non-infringing (MRI Petition for Review, Ex. 2055 in IPR2023-00220; USITC May 8, 2024 Notice at 3).
• 2023-11-27 — MRI petitioned the Commission for review of the FID (challenging infringement, validity, and the redesign rulings) (MRI Pet., public version on file in IPR2023-00220).
• 2024-02-28 — The Commission declined to review the FID, adopted the no-violation finding, and terminated the investigation (89 Fed. Reg. 15896–98, Mar. 5, 2024).
• 2024-03-13 — MRI filed a petition for reconsideration under 19 C.F.R. § 210.47, limited to the redesign finding; Samsung, Coates US, and Palmer Digital opposed (Mar. 18, 2024).
• 2024-05-08 — Commission denied reconsideration, finding the petition raised no new question under Rule 210.47 (USITC Notice, May 8, 2024).
• Federal Circuit: MRI appealed the ITC determination (No. 24-1749), but per the prior case summary the appeal was voluntarily dismissed in August 2024. A related CAFC docket, MRI v. Samsung Electronics Co., Ltd., No. 24-2231, filed 2024-08-16 (Justia/docket of CAFC), post-dates the district court's March 2024 close and is most plausibly MRI's appeal from the E.D. Tex. final disposition — but I could not verify its subject matter or outcome, and it should be treated as unconfirmed.

C. PTAB IPRs on the asserted patents

• 2022-11-22 — Samsung filed IPR petitions, including IPR2023-00199 challenging claims 1, 4, 7, and 8 of the '595 patent (Board panel: Judges Lee, Kokoski, Hudalla). Companion IPRs (IPR2023-00220 on the '322 patent; -00221; -00254; -00255) challenged the rest of the family.
• 2023-06-20 — Board instituted review in IPR2023-00199 on all challenged claims and all grounds.
• 2024-06-18 — Final Written Decision (Paper 56): all challenged claims of the '595 patent held unpatentable as obvious over combinations including Kim, Na, Takeuchi, Hong, and Takahashi. The Board held a consolidated hearing with the related '322 patent IPR (IPR2023-00220).
• Federal Circuit: MRI appealed (No. 24-2228, captioned MRI v. Squires with USPTO Director participation), and the CAFC affirmed in a nonprecedential opinion dated 2026-03-31 (per prior case summary; cafc.uscourts.gov). A companion director-intervenor appeal, No. 24-2224 (MRI v. Squires), involving a related IPR, was still active through 2025 per CourtListener; its final disposition is not reflected in my search results.

II. Outcome

• ITC (337-TA-1331): No violation — final, effective 2024-02-28 (investigation terminated), reconsideration denied 2024-05-08; MRI's CAFC appeal (No. 24-1749) voluntarily dismissed August 2024. MRI's bid for a limited exclusion order and cease-and-desist orders failed.
• PTAB (IPR2023-00199): All challenged '595 claims (1, 4, 7, 8) invalid as obvious; Final Written Decision 2024-06-18; affirmed by the Federal Circuit 2026-03-31.
• District court (2:22-cv-00320): Docket closed as of ~March 2024 per RPX/Ex Parte, aligning with the post-ITC, post-institution window — consistent with the case being dismissed or resolved once the ITC no-violation finding and IPR institution/decisions eliminated the substantive infringement and validity positions. The precise final disposition (settlement vs. stipulated dismissal vs. judgment) is not confirmed in my sources, and CAFC No. 24-2231's relationship to any district-court judgment remains unverified.

III. Net effect

The coordinated Samsung defense produced a clean sweep on the '595 patent and the broader five-patent family: PTAB invalidation of the challenged '595 claims (affirmed on appeal), an ITC no-violation determination adopted by the Commission, and closure of the parallel East Texas case. For the '595 patent specifically, the operative final word is the PTAB's June 18, 2024 Final Written Decision, now affirmed by the Federal Circuit, which forecloses reassertion of those claims against Samsung in any future district court or ITC proceeding.

IV. Source notes & unresolved items

• Verified: Complaint filing and party/judge data (Unified Patents, RPX, Ex Parte); ITC timeline and Markman schedule (USITC May 8, 2024 Notice; 89 Fed. Reg. 15896; ITC Order Ex. 1034); FWD and institution dates (prior case summary; PTAB docket).
• Not verified / flagged: (1) the district court's answer/counterclaim docket, any motions to dismiss/transfer/stay/SJ, and district-court Markman proceedings — no reliable public docket text was retrievable; (2) the final E.D. Tex. disposition order; (3) the subject matter and disposition of CAFC No. 24-2231; (4) disposition of companion IPR appeals (e.g., CAFC No. 24-2224). These items should be checked against PACER/CM-ECF and the CAFC docket before being relied on.

Interpretive note on "plaintiff" in this record

This matter is a PTAB IPR (IPR2023-00199), where the parties are technically Petitioner (Samsung) and Patent Owner (MRI) — not plaintiff/defendant. The case metadata for this record labels Samsung as "Plaintiff" and MRI as "Defendant" (following the IPR caption, Samsung Electronics Co., Ltd. et al. v. Manufacturing Resources International, Inc.), while the underlying E.D. Tex. infringement suit MRI filed (No. 2:22-cv-00320) has MRI as the actual plaintiff. I address both readings below so the answer is usable either way, and I flag clearly what is sourced versus unverified. I did not invent any attorney names.

1. Samsung (petitioner / "plaintiff" as captioned in this IPR) — counsel of record: NOT CONFIRMED in this session

The searches available to me did not return Samsung's lead/backup counsel of record for IPR2023-00199. The petition (Paper 1, filed Nov. 22, 2022) and Samsung's mandatory notices would name them on the PTAB docket, but I could not verify the names from the sources retrieved (search limits were reached). I decline to guess — PACER/PTAB's API or the IPR2023-00199 docket sheet (entries 1–2) would confirm. Do not treat any name in this section as sourced.

2. MRI (patent owner; and the actual plaintiff in the underlying E.D. Tex. patent-infringement action 2:22-cv-00320) — counsel of record: CONFIRMED for the PTAB side

MRI's PTAB counsel across the MRI/Samsung IPR family was Kilpatrick Townsend & Stockton LLP, per MRI's Patent Owner Mandatory Notice (filed Feb. 3, 2023), which identifies the same lead/backup structure used in the related IPRs (the notice I retrieved is docketed in IPR2023-00221, a companion case in the same campaign; the same firm and team represented MRI in the family including IPR2023-00199) — source: DocketAlarm PDF of the mandatory notice, https://www.docketalarm.com/cases/PTAB/IPR2023-00221/...

• John C. Alemanni — Lead Counsel for Patent Owner MRI. Kilpatrick Townsend & Stockton LLP, Raleigh, NC (4208 Six Forks Rd., Suite 1400). Reg. No. 47,384. Experienced IP litigator who has led MRI's defense of its display-cooling patent portfolio in multiple inter partes reviews.
• Carl Sanders — Backup Counsel. Kilpatrick Townsend, Raleigh, NC (same office). Reg. No. 57,203.
• Michael T. Morlock — Backup Counsel. Kilpatrick Townsend, Atlanta, GA (1100 Peachtree St. NE, Suite 2800). Reg. No. 62,245. Atlanta-based patent litigator handling the firm's work for MRI (MRI is an Alpharetta, GA company, making Atlanta-based local counsel a natural fit).
• Courtney Dabbierre — Backup Counsel. Kilpatrick Townsend, Atlanta, GA (same office). Reg. No. 74,185.

Role caveat: These are MRI's PTAB/patent-owner counsel (the adverse party to the captioned "plaintiff" Samsung in this IPR). They are confirmed from MRI's own mandatory notice; the notice also confirms MRI's parallel E.D. Tex. designation of the same litigation, Manufacturing Resources International, Inc. v. Samsung Electronics Co., Ltd. et al., Case No. 2:22-cv-00320 (E.D. Tex.), as the co-pending case — but it does not list the separate district-court attorneys of record who signed the E.D. Tex. complaint.

3. Explicitly unverified items

• MRI's district-court litigation counsel in E.D. Tex. No. 2:22-cv-00320 (i.e., the attorneys who signed the infringement complaint before Judge Gilstrap) — not confirmed from sources retrieved this session. RPX Insight shows the case (filed Aug. 19, 2022; latest docket entry Mar. 12, 2024) but the snippet does not list counsel.
• Samsung's PTAB lead/backup counsel in IPR2023-00199 — not confirmed; the petition and Petitioner mandatory notices (PTAB Papers 1–2) are the authoritative source and were not retrievable within my search limit.
• MRI's ITC counsel (Investigation No. 337-TA-1331) — not confirmed in the sources returned.

Bottom line

If "plaintiff" means the captioned petitioner here (Samsung), its counsel of record must be pulled from the PTAB docket (Papers 1–2 of IPR2023-00199) and is unverified in this session — no names should be attributed. If "plaintiff" means MRI (the party that brought the underlying infringement case), its PTAB-side counsel is confirmed as Kilpatrick Townsend (Alemanni lead; Sanders, Morlock, Dabbierre backup) as detailed above, while its E.D. Tex. district-court attorneys of record remain unverified.

Counsel of record — scope note and verified findings

Threshold ambiguity. This docket (IPR2023-00199) is an inter partes review before the PTAB, which has no "defendants" — the parties are Petitioner (Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.) and Patent Owner (MRI). The Samsung entities are the defendants in the parallel infringement action that triggered this IPR, MRI v. Samsung Electronics Co. et al., No. 2:22-cv-00320 (E.D. Tex.), and they are the respondent-side entities in ITC Inv. No. 337-TA-1331. I therefore read the request as asking for counsel for the Samsung entities (defendants below / petitioners here), with MRI's counsel noted for completeness.

Verified counsel (grounded in this session's search results)

1. Srikanth K. Reddy — backup counsel for Samsung (Petitioner/defendant side) in the IPRs

• Role: Pro hac vice backup counsel only (not lead; lead must be a registered practitioner per Board order).
• Firm/office: Not confirmed from available sources — the Board's order (IPR2023-00199 et al., Order Conditionally Granting Petitioner's Motions for Pro Hac Vice Admission of Srikanth K. Reddy, ~Dec. 11, 2023) does not state his firm.
• Experience note: His admission declaration stated he had never been suspended and was subject to the USPTO Rules of Professional Conduct; the Board found he had "sufficient legal and technical qualifications," "demonstrated litigation experience and familiarity with the subject matter," and granted admission conditionally because his declaration used outdated Unified Patents language (e.g., "suspended from practice" instead of "suspended or disbarred," and Code of Professional Responsibility instead of USPTO Rules). He was identified in Samsung's Mandatory Notices (Paper 2 in the related proceedings) and admitted across all five coordinated IPRs (IPR2023-00199, -00220, -00221, -00254, -00255).

2. Steven Borgman — counsel for MRI (plaintiff in the underlying infringement case; Patent Owner here)

• Role: Signatory/filer of the E.D. Tex. complaint for MRI.
• Firm: Kilpatrick Townsend & Stockton (per contemporaneous press report of the Aug. 19, 2022 filing and the Patexia docket listing, which attributes the complaint and subsequent filings to "Borgman, Steven").
• Note: This is the adverse party's counsel, included only to orient the user — not defendant-side counsel.

What I could not verify (searched; no reliable result)

• Samsung's lead counsel of record in IPR2023-00199 — the Board order confirms a registered-practitioner lead counsel existed, but I could not retrieve the mandatory-notice paper (Paper 2) naming that lead and the remaining backup counsel. Do not treat any name as confirmed; the FWD (Paper 56) and related orders would list them, but those papers were not accessible in my searches this session.
• Samsung's defense counsel of record in the E.D. Tex. action (2:22-cv-00320) — the complaint docket confirms MRI's counsel (Kilpatrick Townsend) but defense appearances were not captured in the search results. A news summary of the filing noted "counsel for the defendants has not yet appeared" as of the filing date. Given the case's later posture (parallel ITC proceeding, IPR institution June 2023, and RPX showing the district docket's last entry around March 2024), the district case may have been stayed or resolved, but I cannot confirm the final district-court disposition or Samsung's district counsel — flagging this as unresolved rather than guessing.
• Samsung's ITC counsel in Inv. No. 337-TA-1331 — not retrieved.

Bottom line

The only Samsung-side counsel I can affirmatively name from source-grounded evidence is Srikanth K. Reddy (backup, pro hac vice, across the five coordinated IPRs including IPR2023-00199). His firm is unconfirmed in the available materials. Samsung's lead IPR counsel and its E.D. Tex./ITC defense counsel remain unidentified in this session's sources; if you need those names, the authoritative references are (1) the Mandatory Notices in IPR2023-00199 (Paper 2, PTAB) and (2) the E.D. Tex. docket entries for notices of appearance in 2:22-cv-00320 (PACER), neither of which I could fully retrieve within the search limits.