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

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
MANUFACTURING RESOURCES
INTERNATIONAL, INC.,
Appellant
v.
JOHN A. SQUIRES, UNDER SECRETARY OF
COMMERCE FOR INTELLECTUAL PROPERTY
AND DIRECTOR OF THE UNITED STATES
PATENT AND TRADEMARK OFFICE,
Intervenor
______________________
2024-2228, 2024-2229
______________________
Appeals from the United States Patent and Trademark
Office, Patent Trial and Appeal Board in Nos. IPR2023-
00199, IPR2023-00220.
______________________
Decided: March 31, 2026
______________________
J OHN C. ALEMANNI, Kilpatrick Townsend & Stockton
LLP, Raleigh, NC, argued for appellant. Also represented
by CARL SANDERS ; MATTHEW MEYER , Menlo Park, CA;
MICHAEL T. MORLOCK , D AVID A. REED, Atlanta, GA.
F AHD H. P ATEL , Office of the Solicitor, United States
Patent and Trademark Office, Alexandria, VA, argued for
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intervenor. Also represented by P ETER J. A YERS , N ICHOLAS
T HEODORE M ATICH , IV, ROBERT J. MCMANUS , MICHAEL
T YLER.
______________________
Before P ROST , T ARANTO, and STOLL , Circuit Judges.
T ARANTO, Circuit Judge.
Manufacturing Resources International, Inc., (MRI)
owns U.S. Patent Nos. 8,854,595 and 9,173,322, which de-
scribe and claim cooling systems for electronic displays.
The patented cooling systems use a “constricted convection
plate” to keep cool air flowing across the back of a hot dis-
play surface. Samsung Electronics Co. successfully peti-
tioned the Patent and Trademark Office (PTO) to institute
inter partes reviews (IPRs) of claims 1, 4, 7, and 8 of the
’595 patent and claims 1–5, 7–13, and 16 of the ’322 patent
on obviousness grounds. The PTO’s Patent Trial and Ap-
peal Board (Board) found, as relevant here, that the prior
art discloses a constricted convection plate and that MRI’s
objective-indicia evidence was entitled to little weight, and,
as a result, the Board held all challenged claims unpatent-
able. Samsung Electronics Co. v. Manufacturing Resources
International, Inc., No. IPR2023-00199 (P.T.A.B. June 18,
2024); Samsung Electronics Co. v. Manufacturing Re-
sources International, Inc., No. IPR2023-00220 (P.T.A.B.
June 18, 2024). MRI appeals. We affirm.
I
The ’322 patent issued from a continuation application
of the application that issued as the ’595 patent, so the two
patents share a specification. ’322 patent, col. 1, lines 7–9.
The patents, both titled “Constricted Convection Cooling
System for an Electronic Display,” describe a problem of
removing heat from displays, especially large displays ex-
posed to sunlight, and a prior-art solution of “cool[ing the]
entire interior of the display” by using fans to move air
“through as many sidewalls of the display as possible.” ’595
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patent, col. 1, line 52, through col. 2, line 29. The patents
assert that better cooling is achievable by instead inducing
“constricted convection” immediately behind the display
surface. Id., col. 2, lines 30–59.
Constricted convection, as the name implies, results
from reducing the space available for airflow and moving
air through the resulting narrow space, which the patents
term a “constricted convection channel.” Id., col. 4, line 66,
through col. 5, line 21. The constricted convection channel
is defined on one side by the hot “posterior display surface”
and on an opposite side by a “constricted convection plate”
that restricts the depth of the space for airflow to a few
inches or less. Id. The constricted convection plate may
have “access apertures,” i.e., holes, which may “allow ac-
cess to hardware found on the display posterior” and which
“may be plugged before operation [of the cooling system] to
maintain directed contact between” the cool air moving
through the channel and the posterior display surface. Id.,
col. 5, lines 6–12.
Claim 1 of the ’595 patent is illustrative for purposes of
the main issue presented to us regarding both patents:
1. A system for cooling an electronic display having
a posterior display surface and contained within a
housing, the system comprising:
a constricted convection plate placed posterior
to the posterior display surface;
two side panels placed adjacent to the constricted
convection plate and the posterior display surface,
defining a constricted convection channel having
an entrance and an exit; and
a fan placed to draw air from outside of the housing
through the constricted convection channel.
Id., col. 9, line 63, through col. 10, line 6 (emphasis added).
Each independent claim—claims 1, 4, and 9 of both
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patents—has a relevantly similar “constricted convection
plate” limitation. The ’595 patent’s claim 8, which depends
on claim 4, presents an additional issue based on its limi-
tation concerning access apertures:
8. The [liquid crystal display] from claim 4 further
comprising:
a plurality of access apertures through the con-
stricted convection plate.
Id., col. 10, lines 38–40.
In late 2022, Samsung petitioned the PTO to institute
two IPRs, one for each patent, seeking cancellation on ob-
viousness grounds of ’595 claims 1, 4, 7, and 8 and ’322
claims 1–5, 7–13, and 16. J.A. 1, 79; see J.A. 194, 198. As
relevant here, Samsung argued that each of two prior-art
references—Kim, which is U.S. Patent No. 7,800,706, and
Na, which is unexamined Korean Patent Application Pub-
lication No. 10-2006-0016469—discloses the claimed “con-
stricted convection plate.” See J.A. 34–40, 93–98, 114–17.
The Board, on behalf of the PTO’s Director, instituted both
IPRs in June 2023. J.A. 194, 198.
The first of the references, Kim, describes a display
with a backlight and, behind the backlight, a “cooling fan
unit that is combined to [a] shield cover.” J.A. 1692, Ab-
stract. The shield cover has “a plurality of air slits through
which air generated by the cooling fan unit comes in and
out.” J.A. 1699, col. 2, lines 12–15. Samsung argued to the
Board that the shield cover constitutes a constricted con-
vection plate (as claimed by MRI) because Kim says that
the shield cover “may be formed in diverse shapes such that
the flowing air . . . can be efficiently guided.” See J.A. 116–
17 (quoting J.A. 1700, col. 4, lines 61–63).
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The second reference, Na, describes a backlight for a
liquid crystal display. J.A. 1721. The backlight has a col-
lection of light-emitting diodes, which generate heat. J.A.
1725. To dissipate the heat, Na teaches using fans to move
air through an “inner space” behind the backlight, defined
by a “bottom plate” and “sidewalls”; “air is introduced into
the inner space [ ] through [ ] through-holes,” as shown in
Na’s Figures 1 (below, left) and 3 (below, right). J.A. 1725,
1733–34.
Samsung argued to the Board that the bottom plate (el-
ement 210) constitutes a constricted convection plate as
claimed by MRI, J.A. 590–97, 1086–87, and that the
through-holes (elements 212) constitute the MRI-claimed
access apertures, J.A. 617–18. Although Na’s figures de-
pict through-holes in the bottom plate, the written descrip-
tion says that “through-holes may be further formed in the
first to fourth sidewalls, or may be formed only in the first
to fourth sidewalls.” J.A. 1725, 1726 (emphasis added);
J.A. 1727 (similar). Based on that disclosure, Samsung ar-
gued that a relevant artisan would have understood Na to
disclose an embodiment where the bottom plate has no
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holes, which also teaches the claimed constricted convec-
tion plate. J.A. 592–93, 1317.
MRI, in response, argued that Na’s through-holes and
Kim’s air slits would prevent constricted convection. J.A.
752–56, 1249, 1257. Further, MRI contended that even an
embodiment of Na without through-holes in the bottom
plate would not create constricted convection and, regard-
less, that a relevant artisan would not understand Na to
teach such an embodiment. J.A. 755–56, 862–63, 1369–70.
MRI also attempted to show the nonobviousness of the
challenged claims with objective indicia. It alleged that,
before the creation of MRI’s patented cooling system, there
had been a long-felt need for large displays capable of ef-
fectively dissipating heat when used outdoors, and that
Samsung had tried to develop displays to meet that need,
but its efforts were both technically flawed and commer-
cially unsuccessful. See J.A. 764–67, 1277–1280. MRI
added that, after the invention of the patented cooling sys-
tems, a Samsung employee praised MRI’s accomplish-
ments as “impressive and unique,” and others in the
industry licensed the patents. J.A. 773–74, 1289–90. MRI
also asserted that Samsung, rather than take a license, ac-
quired patent-practicing displays, tore them down to learn
how they worked, copied the cooling system, and deployed
infringing products that enjoyed immediate commercial
success. J.A. 767–73, 1280–89.
The Board issued two final written decisions in June
2024, each holding all challenged claims unpatentable.
J.A. 1, 78. The Board found that both Na and Kim disclose
the claimed constricted convection plate, crediting Sam-
sung’s expert’s testimony. J.A. 30–40, 93–98, 114–17. The
Board also found that Na discloses the constricted convec-
tion plate with access apertures required by claim 8 of the
’595 patent. J.A. 72–73. As to objective indicia, the Board
assigned MRI’s evidence “little or no weight.” J.A. 58; see
J.A. 135–50. It found that Samsung did not copy the
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invention because Samsung had completely designed the
allegedly infringing products’ cooling system before the as-
serted tearing down of a patent-practicing display. J.A.
48–50, 141–43. For the rest of MRI’s objective-indicia evi-
dence, the Board determined that MRI had not established
a nexus to the claims. See J.A. 42–57, 135–49.
MRI timely appealed from both final written decisions.
We consolidated the appeals, and Samsung thereafter no-
tified us of its nonparticipation in the case. The Director
timely intervened as of right to defend the Board’s deci-
sions. See 35 U.S.C. § 143. We have jurisdiction under 28
U.S.C. § 1295(a)(4)(A) and 35 U.S.C. §§ 141(c), 319.
II
We review the Board’s legal determinations without
deference and its factual findings for substantial-evidence
support. Corephotonics, Ltd. v. Apple Inc., 84 F.4th 990,
1001 (Fed. Cir. 2023). Substantial evidence is “such rele-
vant evidence as a reasonable mind might accept as ade-
quate to support a conclusion,” Consolidated Edison Co.
v. National Labor Relations Board, 305 U.S. 197, 229
(1938), which may be present even if an opposite resolution
of the issue might also be supportable, Consolo v. Federal
Maritime Commission, 383 U.S. 607, 619–20 (1966).
Claim construction based only on intrinsic evidence is
a question of law. Teva Pharmaceuticals USA, Inc.
v. Sandoz, Inc., 574 U.S. 318, 330–31 (2015). Obviousness
is an issue of law whose resolution depends on underlying
findings of fact. Quanergy Systems, Inc. v. Velodyne Lidar
USA, Inc., 24 F.4th 1406, 1414 (Fed. Cir. 2022). “These
facts include the scope and content of the prior art and any
objective indicia of nonobviousness.” Id. at 1414.
The issues presented by MRI’s appeal fall into two cat-
egories. First, MRI makes several arguments about the
claimed constricted convection plate. Second, MRI asserts
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error in the Board’s giving little weight to objective indicia.
We reject MRI’s challenges.
A
With respect to the constricted convection plate re-
quired by all claims at issue, MRI challenges the Board’s
findings that each of Na and Kim discloses that element.
MRI Opening Br. at 29–36, 62–65. With respect to claim 8
of the ’595 patent, which requires a constricted convection
plate with access apertures, MRI argues that the Board’s
finding that the limitation is taught by Na rests on an er-
roneous claim construction and is inconsistent with the
Board’s other reasoning. Id. at 58–61. We disagree with
MRI in both respects.
1
The Board properly found that each of Na and Kim dis-
closes a constricted convection plate. Regarding Na, the
Board found that Na teaches an embodiment of its bottom
plate that “does not include through-holes[ ]” and that the
no-through-holes embodiment “teaches the recited ‘con-
stricted convection plate,’” a finding sufficient to support
its determination regarding Na’s disclosure of the con-
stricted-convection-plate claim limitation without having
to consider alternative embodiments. J.A. 37; see J.A. 95
(similar). Substantial evidence supports that finding.
MRI argues that Na does not disclose a bottom plate
without through-holes because Na’s “objective . . . is to ex-
change as much air as possible” and Na’s disclosure must
be understood in light of that aim. MRI Opening Br. at 35.
But the Board was reasonable in finding otherwise based
on Na’s express teaching that “through-holes ‘may be
formed only in the first to fourth sidewalls,’” i.e., not in the
bottom plate. J.A. 38 (quoting J.A. 1725) (emphasis added
by the Board); see J.A. 95. That reading is further sup-
ported by Samsung’s expert evidence, credited by the
Board, that Na discloses “using a bottom plate [ ] that does
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not have through-holes.” J.A. 38 (quoting J.A. 1642–44
¶ 210); see J.A. 95–96. MRI identifies no evidence that
compels its different interpretation. Nowhere, for example,
does Na specify a minimum acceptable amount of airflow
or say that through-holes in the bottom plate are neces-
sary, and its express disclosures on the point clearly state
that one option is to place through-holes “only” in the side-
walls. J.A. 1725, 1727.
Similarly, substantial evidence supports the Board’s
finding that Kim’s shield cover discloses a constricted con-
vection plate. The Board relied on Kim’s disclosure that
the shield cover “may be formed in diverse shapes such that
the flowing air produced by the cooling fan [ ] can be effi-
ciently guided.” J.A. 116 (quoting J.A. 1700, col. 4, lines
61–63). The Board also credited the testimony of Sam-
sung’s expert that Kim’s disclosure of “efficiently guided”
air teaches that “Kim’s shield cover [ ] guides and constricts
airflow.” J.A. 116–117 (citing J.A. 6775–77 ¶ 131).
MRI contends that the Board erred because “[g]uiding
air and constricting it are two different concepts.” MRI
Opening Br. at 64. But the Board reasonably viewed them
as related. And MRI cites no evidence to rebut the idea
that the narrow space enclosed by Kim’s shield cover is con-
stricted or to contradict the Board’s determination that
Kim’s disclosure about guiding also teaches constricting. A
reasonable factfinder could therefore find, on the record be-
fore the Board, that Kim teaches a constricted convection
plate.
2
MRI contends that the Board erred in holding ’595
claim 8 unpatentable because it misconstrued the term “ac-
cess apertures” and because its obviousness analysis for
claim 8 was inconsistent with that for claim 4, on which
claim 8 depends. We disagree.
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First, we see no error in the Board understanding of
“access apertures.” See J.A. 20–21. Claim 8 incorporates
claim 4’s “constricted convection plate” requirement and
adds a requirement of “a plurality of access apertures
through the constricted convection plate.” ’595 patent, col.
10, lines 38–40. MRI urges that the access apertures, in
light of the specification, must be so sized as to provide ac-
cess to the hardware inside and “must be structured (or
plugged) so that the air flow is maintained” when the cool-
ing system is in operation. MRI Opening Br. at 59–60 (re-
lying on ’595 patent, col. 5, lines 6–12 and col. 6, lines 25–
29). The Board properly rejected the suggested narrowing.
The specification, while reciting hardware access as an ex-
ample, “does not state that ‘access’ through the apertures
must relate to hardware access or any other particular type
of access.” J.A. 21. And the specification indicates that
plugging the access apertures is optional. ’595 patent, col.
5, lines 10–12 (“The access apertures [ ] may be plugged be-
fore operation to maintain directed contact between the re-
frigerated air and the posterior display surface[.]”
(emphasis added)). We do not see a sufficient basis for
reading MRI’s proposed limitation into the claims.
Second, MRI’s argument that the Board’s decision in
the ’595 patent IPR was internally inconsistent is incorrect
(and it may well have been forfeited, which we need not
decide). According to MRI, the Board’s determination that
claim 4 would have been obvious “rests squarely” on the
“embodiment of Na in which the bottom plate does not con-
tain any through[-]holes.” MRI Opening Br. at 61; see id.
at 12–14. Yet, for dependent claim 8, MRI notes, the Board
was “persuaded that Na’s through-holes [ ] teach the re-
cited ‘access apertures through the constricted convection
plate[.]’” Id. at 61 (quoting J.A. 72). MRI asserts that the
Board’s reliance on two different Na embodiments creates
an inconsistency because, MRI says, the Board, when dis-
cussing claim 4, found that only Na’s bottom plate without
holes teaches the constricted convection plate. Id. at 60–
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61. But the crucial premise of MRI’s argument is wrong:
The Board did not find that only Na’s bottom plate without
holes teaches the claimed constricted convection plate, so
the complained-of inconsistency is illusory.
Before the Board, Samsung argued that both Na’s bot-
tom plate with holes and Na’s bottom plate without holes
taught that claim limitation. J.A. 590–97, 611, 806–807,
940.1 MRI contested Samsung’s theory involving Na’s bot-
tom plate with holes on two bases: first, that a plate with
holes could not define a constricted convection channel
with a single entrance, and second, that such a plate would
not constrict airflow. J.A. 752–58; 862–63.
The Board expressly rejected both of those arguments
by MRI. The Board dealt with the former by declining to
construe the claimed constricted convection channel as re-
quiring only a single entrance. J.A. 15–18. As to the latter,
in a portion of its analysis discussing the constricted con-
vection channel, the Board wrote,
[W]e are persuaded . . . that an ordinarily skilled
artisan would have understood that the bottom
plate [ ] constricts airflow in order to achieve the
desired convective cooling effect. This is particu-
larly true given [Samsung’s] proposed modification
to not include through-holes [ ] in [the] bottom
plate [ ] based on Na’s teachings.
J.A. 39 (quoting J.A. 592 (’595 IPR petition, advancing ob-
viousness theory based on Na’s bottom plate with holes))
(internal quotation marks and citation omitted).2 The
1 The parties and the Board dealt with the con-
stricted convection plate as part of the claim 1 analysis, in-
corporated by reference for claim 4. See J.A. 66.
2 We understand the Board reference to “proposed
modification” to refer merely to the modification of the
with-holes-in-bottom version depicted in Na’s Figures 2
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Board’s reasoning there applies to both the with-holes-in-
bottom and the without-holes-in-bottom embodiments in
Na—“particularly” to the latter but not exclusively so. In-
deed, it is primarily a rejection of the MRI argument that
was directed to Na’s embodiment with holes as not disclos-
ing the claim-required constricted convection plate. And
the Board went on to find that Na also discloses “side pan-
els,” an “entrance,” and an “exit” required by the claims,
and in doing so referred to the bottom plate, without limi-
tation, as the claimed constricted convection plate. J.A. 39
(“[The side panels] are adjacent to [the] bottom plate [ ] (the
recited ‘constricted convection plate)[.]’”).
For those reasons, we reject MRI’s crucial premise that
the Board, in discussing claim 4, found that only Na’s bot-
tom plate without holes discloses the constricted convec-
tion plate. With that premise rejected, we reject MRI’s
argument of internal inconsistency in the Board’s decision
when it relied on the with-holes embodiment of Na in find-
ing claim 8 unpatentable.
B
MRI challenges the Board’s assignment of little weight
to the objective indicia on which MRI relied. It argues that
the Board erred in finding that MRI did not establish a
nexus between its evidence and the challenged claims.
MRI Opening Br. at 36–53, 65. MRI further contends that
the Board’s analysis was insufficiently developed to enable
our review. Id. at 53–56, 65. These arguments lack merit.
In order for evidence of objective indicia to be accorded
substantial weight, the proponent must show a nexus be-
tween the evidence and the claimed invention in one of two
and 3, see J.A. 31, 1734, to reflect the no-holes-in-bottom
embodiment taught in the description in Na at J.A. 1725,
as discussed above. The word “modification” here does not
refer to modifying what Na as a whole teaches.
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ways. See Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366,
1373 (Fed. Cir. 2019). A nexus exists for an objective indi-
cium if it is the “direct result of the unique characteristics
of the claimed invention.” In re Huang, 100 F.3d 135, 140
(Fed. Cir. 1996). When objective indicia relate to a product
that “is the invention” because it “is coextensive with the
claims,” there is a rebuttable presumption of nexus. Fox
Factory, 944 F.3d at 1373 (citations omitted). Where a
product embodying the invention has unclaimed features,
it is not coextensive with the invention unless the un-
claimed features are relevantly “insignificant.” See id. at
1374.
Here, the Board properly found that MRI was not enti-
tled to a presumption of nexus for its evidence of the com-
mercial success of the invention. In both IPRs, MRI argued
that certain commercially successful Samsung displays in-
fringed specific claims and asserted, without additional
analysis, that the displays were “coextensive with those
claims, and there is a nexus[.]” J.A. 1285; see J.A. 770 (sim-
ilar); see also J.A. 771, 1287 (referring merely to “Samsung
. . . products which infringe” and “Samsung’s infringing [ ]
products”). But even if they infringe, the Samsung prod-
ucts have features other than the claimed system for cool-
ing an electronic display—saliently, they have electronic
displays. MRI made no showing that the qualities of the
electronic displays themselves were insignificant to the
commercial success of Samsung’s products. J.A. 53–54,
145–47; see J.A. 991–96, 1017–18. Such a showing was a
prerequisite to a presumption of nexus, so the Board did
not err in finding MRI’s evidence insufficient to establish
the presumption.
The Board also did not err in finding that MRI failed to
prove a nexus by showing that the objective indicia were
the direct result of the unique characteristics of MRI’s in-
vention. In particular, MRI has relied heavily for its nexus
contention (relating, e.g., to Samsung’s commercial suc-
cess) on Samsung’s tear-down of a competing patent-
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practicing product to discover the now-claimed elements.
See Oral Arg. at 10:10–12:40, https://www.cafc.
uscourts.gov/oral-arguments/24-2228_062026.mp3. The
Board, however, found that Samsung’s allegedly infringing
displays were completely designed before the teardown.
J.A. 48–50; 141–43. And, contrary to MRI’s incorrect state-
ment that only “bare assertions” support that finding, MRI
Opening Br. at 51, the Board cited substantial evidence in
the form of credible deposition testimony by a witness with
relevant personal knowledge to find that no copying took
place, see J.A. 49, 142–43. In light of that well-supported
finding, the Board reasonably found no sufficient connec-
tion between MRI’s evidence of objective indicia of nonob-
viousness and the teardown. Similarly, MRI has not shown
error in the Board’s finding of insufficient nexus between a
Samsung employee’s vague praise for MRI and the features
claimed in the patents at issue here. Thus, the Board did
not err in determining that MRI failed to establish a nexus.
Finally, we do not find that the Board inadequately ex-
plained how it weighed the objective indicia. The Board’s
decisions “enable meaningful judicial review.” Rovalma,
S.A. v. Bohler-Edelstahl GmbH, 856 F.3d 1019, 1024 (Fed.
Cir. 2017). In each of its decisions, the Board correctly
stated the principle that objective-indicia evidence, in the
absence of a nexus to the claimed invention, is not to be
accorded substantial weight. J.A. 44; see J.A. 136. It then
carefully canvassed MRI’s evidence and arguments, ex-
plained why it did not find a nexus, and said that it was
not giving objective indicia substantial weight. J.A. 42–57,
135–49. As the foregoing discussion demonstrates, that
analysis is amenable to our review. We therefore affirm
the Board’s determination to give little weight to objective
indicia.
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III
We have considered MRI’s remaining arguments and
find them unpersuasive. For the foregoing reasons, we af-
firm the decisions of the Board.
AFFIRMED
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