Invalidity dossier

US 9173322

Constricted convection cooling system for an electronic display

Current assignee: Manufacturing Resources International, Inc.

Added 9/1/2026, 12:48:11 AM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by Manufacturing Resources International, Inc.High-Tech (T)

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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US Patent 9,173,322 — Summary

Bibliographic data

Field Value
Patent number US 9,173,322 B2 (US9173322B2)
Title Constricted convection cooling system for an electronic display
Inventor William Dunn
Assignee (original & current) Manufacturing Resources International, Inc. (MRI)
Application US 14/508,621, filed October 7, 2014 (a continuation of US 12/411,925, now US 8,854,595, filed Mar. 26, 2009)
Issue date October 27, 2015
Earliest priority date March 3, 2008 (via the provisional/continuation chain)
Status Active as of the last USPTO record shown, with anticipated expiration listed around September 19, 2028 (subject to terminal disclaimer/term-adjustment caveats — treat as approximate)
Examiner Jerry Blevins (per Unified Patents portal)

Abstract (verbatim): "Preferred embodiments provide a cooling system for an electronic display. A constricted convection plate is used to force cooling air against a posterior surface of the electronic display. Fans may be used to propel or pull air between the constricted convection plate and the rear surface of an electronic display. A refrigeration unit or thermoelectric module may be employed to cool or heat the air traveling through the constricted convection channel. Some embodiments include a closed loop which extracts heat (or adds heat) to the front display surface."

Independent claims (claims 1, 4, and 9; 16 claims total)

  • Claim 1 — System for cooling a housed display. An electronic display having a posterior display surface is contained within a housing. A constricted convection plate is placed posterior to (behind) the display surface, covering the majority of it. At least one bracket connects the display surface to the plate, and a fan is placed to draw ambient air between the plate and the rear posterior (i.e., through the narrow channel defined between them). In plain terms: a rear cover plate mounted close behind the display creates a thin airflow channel, and a fan pulls outside air through that channel to cool the display's backside.

  • Claim 4 — LCD with LED backlight (apparatus). A liquid crystal display comprising a liquid crystal stack and a backlight assembly behind it. The backlight has a PCB with front and back sides, LEDs mounted on the front side, and a posterior surface on the rear side of the PCB. A constricted convection plate sits behind and substantially parallel to that posterior PCB surface, with a fan positioned to draw air between the plate and the posterior surface. In plain terms: the claimed cooling is applied directly to the rear metal/PCB surface of an LED backlight.

  • Claim 9 — Means-plus-function system. An electronic display having a front display surface and a posterior surface where no electronics are mounted. A constricted convection plate behind the posterior surface covers a majority of it, and there is a means for forcing air between the plate and the posterior surface. In plain terms: this claim covers the same rear-plate cooling concept but is not limited to a fan per se — any air-forcing means (e.g., fans, blowers) is covered, on a display whose rear surface carries no electronics.

CAFC 2026 docket activity (directly on this patent)

  • Manufacturing Resources International, Inc. v. Squires, No. 24-2228 (companion 24-2229), U.S. Court of Appeals for the Federal Circuit, origin: PTO (PTAB IPR appeal). Nonprecedential opinion issued March 31, 2026 (2026 WL 879712; Judge Taranto; judgment entered same date). The court affirmed the PTAB's final written decisions in IPRs (including IPR2023-00220) that the challenged claims of both US 8,854,595 and US 9,173,322 were unpatentable as obvious over prior art (Korean references "Kim" and "Na"). Samsung withdrew from the appeal; the USPTO Director intervened to defend the Board. The court rejected MRI's arguments on: (1) whether the prior art disclosed a "constricted convection plate," (2) the Board's construction of "access apertures" (dependent claim 8 of the '595; MRI's narrow construction was rejected), and (3) MRI's objective-indicia (commercial success/copying) evidence, which lacked a proven nexus to the claimed invention. This decision means the patent's challenged claims (the '322's claims 1–5, 7–13, and 16) stand invalidated as obvious, subject to any further review (e.g., certiorari), of which I have no information.

Related litigation (context)

  • ITC Inv. No. 337-TA-1331 (MRI v. Coates Signco / Samsung): ALJ found no violation; MRI's appeal in 24-1749 (Fed. Cir.) was voluntarily dismissed Aug. 29, 2024 under Rule 42(b), each side bearing its own costs.
  • District-court cases referencing this patent family include Delaware 1:17-cv-00269 and Texas Eastern 2:22-cv-00320.
  • This patent is the subject of the same family as US 9,894,800 and US 10,506,738 (continuations), and US 8,854,595 (parent).

Uncertainty notes

  • I could not directly query the USPTO Patent Center in this session; the bibliographic data above is sourced from Google Patents (full-text record), Unified Patents, and secondary patent databases, which are consistent with each other. Small discrepancies in day-level dates exist among sources (e.g., Unified Patents lists grant date as 2015-10-26 vs. Google's 2015-10-27; the official publication date is October 27, 2015).
  • The CAFC opinion is nonprecedential and I have not reviewed the full PDF; the summary relies on the CAFC website docket entry, CourtListener, and contemporaneous case summaries (April 2026).
  • I found no CAFC docket activity specific to this patent that is pending as of April 2026 beyond the 24-2228/24-2229 affirmance and the earlier dismissed 24-1749 appeal.

Generated 9/1/2026, 4:49:14 AM

Cases on file (1)

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Specific litigation cases in our database that name US patent 9173322. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

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I'll research litigation involving US Patent 9,173,322. Let me search several sources.

I have solid leads. Let me dig deeper into the specific cases and their current status.

Based on my research (prioritizing live search results from Unified Patents, CAFC, CourtListener, UniCourt, Patexia, the Federal Register, and PatSnap), here is the known litigation involving US Patent No. 9,173,322 ("Constricted Convection Cooling System for an Electronic Display," owned by Manufacturing Resources International, Inc. ["MRI"]).


1. MRI v. Civiq Smartscapes, LLC et al. — D. Del.

  • Plaintiff: Manufacturing Resources International, Inc.
  • Defendants: Civiq Smartscapes, LLC; Civiq Holdings, LLC; Comark, LLC; Comark Holdings, LLC
  • Jurisdiction: [U.S. District Court for the District of Delaware (Judge Richard G. Andrews)](/courts/district-of-delaware-judge)
  • Case No.: 1:17-cv-00269-RGA
  • Filing date: March 14, 2017
  • Patents: The '322 patent was one of many MRI cooling patents asserted (claim construction covered the '322 patent along with the '595, '572, '287, '325, '633, '108, and '917 patents; the case involved up to 18 MRI patents, including 9,173,322).
  • Status/Outcome: Settled — dismissed with prejudice. A joint stipulation of dismissal with prejudice was so ordered on January 24, 2020 (D.I. 364/365), terminating the case. Patexia lists status "Dismissed – Settled."

2. MRI v. [[[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.) — E.D. Tex.

  • Plaintiff: Manufacturing Resources International, Inc.
  • Defendants: Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung SDS Co., Ltd.; Samsung SDS America, Inc.
  • Jurisdiction: U.S. District Court for the Eastern District of Texas (Tyler Division)
  • Case No.: 2:22-cv-00320
  • Filing date: August 19, 2022 (complaint; jury demand same day)
  • Patents: 8,854,595; 9,173,322; 9,629,287; 10,506,740; 11,013,142 (claim charts for the '322 patent were filed with the complaint as Exhibits D–F)
  • Status/Outcome: Open/ongoing as of the last available docket update (UniCourt lists status "Open"). I found no final judgment in my search. Note that this case was filed the same day as the ITC complaint, and the '322 patent has since been held unpatentable in IPR (see below), which would bear on this case's viability.

3. ITC Investigation No. 337-TA-1331 — Certain Outdoor and Semi-Outdoor Electronic Displays

  • Complainant: Manufacturing Resources International, Inc.
  • Respondent(s): Public sources differ. PatSnap's ITC case analysis identifies the respondent as Coates Signco Pty Limited (Australian signage company; Goodwin Procter LLP as counsel), while PatSnap's Federal Circuit summary describes the underlying ITC dispute as involving Samsung outdoor display products — suggesting the investigation may have named multiple respondents, or the two sources are describing related matters. The Federal Register notice of investigation (Sept. 23, 2022, Docket 2022-20607) confirms the '322 patent was asserted (claims 4, 5, 8, 9, 12, 13, and 16) along with the '595, '287, '740, and '142 patents.
  • Jurisdiction: U.S. International Trade Commission (ALJ Monica Bhattacharyya)
  • Case No.: 337-TA-1331
  • Filing date: Complaint filed August 19, 2022; investigation instituted September 19, 2022.
  • Status/Outcome: No violation found. ALJ issued an Initial Determination of no violation on November 13, 2023; the Commission declined to review on February 28, 2024, terminating the investigation without any exclusion order. MRI appealed (see Case 5 below).

4. Samsung Electronics Co., Ltd. et al. v. MRI — PTAB IPR

  • Petitioner: Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (Goodwin Procter LLP)
  • Patent Owner: Manufacturing Resources International, Inc. (Kilpatrick Townsend & Stockton LLP)
  • Jurisdiction: Patent Trial and Appeal Board
  • Case No.: IPR2023-00220 (Patent 9,173,322 B2)
  • Filing date: Petition filed December 5, 2022; institution decision June 20, 2023.
  • Claims challenged: 1–5, 7–13, and 16.
  • Status/Outcome: Final Written Decision (June 18, 2024) holding all challenged claims unpatentable as obvious (primarily over the Kim and Na prior-art references). The Board credited Samsung's expert testimony that both references disclose the claimed "constricted convection plate" and gave MRI's secondary-considerations evidence little weight. This decision was appealed to the Federal Circuit (see Case 6).

5. MRI v. ITC — Federal Circuit Appeal No. 24-1749

  • Appellant: Manufacturing Resources International, Inc.
  • Appellee: U.S. International Trade Commission (underlying investigation 337-TA-1331; Samsung displays per PatSnap's summary)
  • Jurisdiction: U.S. Court of Appeals for the Federal Circuit
  • Case No.: 24-1749
  • Filing date: Appeal docketed around April 2024 (appeal of the ITC no-violation determination).
  • Status/Outcome: Voluntarily dismissed on August 29, 2024, under Fed. R. App. P. 42(b) pursuant to a joint agreement, with each side bearing its own costs. No merits decision; no damages or injunctive relief awarded.

6. MRI v. Squires (Director, USPTO) — Federal Circuit Appeals Nos. 24-2228 & 24-2229

  • Appellant: Manufacturing Resources International, Inc.
  • Appellee/Intervenor: John A. Squires, Under Secretary of Commerce for Intellectual Property and Director of the USPTO (intervening to defend the Board's IPR decisions; Samsung declined to participate after initially being named)
  • Jurisdiction: U.S. Court of Appeals for the Federal Circuit
  • Case Nos.: 24-2228 and 24-2229 (consolidated; these are MRI's appeals of the two IPR Final Written Decisions — the '322 patent IPR was IPR2023-00220, appealed as 24-2229, and the companion '595 patent IPR appeal as 24-2228)
  • Filing date: Appeals filed in 2024 following the June 2024 IPR decisions.
  • Status/Outcome: Affirmed in a nonprecedential opinion issued March 31, 2026. The Federal Circuit rejected MRI's challenges to the Board's constructions and obviousness findings (including the "constricted convection plate" and "access apertures" issues), upholding the Board's determinations that all challenged claims of the '322 patent (and the '595 patent) are unpatentable.

Notes / cautions

  • I excluded the Fiber, LLC v. Ciena/Viavi/Lumentum cases (D. Colo. 13-cv-00840, 15-cv-01743, 15-cv-02135) — those concern U.S. Patent Nos. 6,430,332 and 7,095,917, not 9,173,322, despite the coincidental "332"/"917" numbers.
  • The ITC respondent identification (Coates Signco vs. Samsung) is the one area where sources conflict; the Federal Register confirms the '322 patent was asserted in 337-TA-1331, and I've flagged the discrepancy above rather than resolving it definitively.
  • I found no separate district-court case against Coates Signco on the '322 patent, and no other district-court or PTAB matters for this patent number beyond those listed.

Bottom line: US 9,173,322 has been litigated in at least six proceedings — the settled Delaware case (2017–2020), the open E.D. Tex. Samsung case (2022–present), the ITC investigation (no violation, 2022–2024), a PTAB IPR (all claims invalidated, 2022–2024), and two Federal Circuit appeals (one dismissed in 2024, one affirmed in March 2026). The patent's asserted claims have been held unpatentable in IPR, and that determination was affirmed by the Federal Circuit on March 31, 2026.

Generated 9/1/2026, 4:49:54 AM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Manufacturing Resources International, Inc.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

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Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

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Prior art

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Obviousness

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Extensions

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Derivative works

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This patent in court (1)

1 tracked lawsuit name US 9173322.