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

NOTE: This disposition is nonprecedential.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
______________________
2024-2224, 2024-2231
______________________
Appeals from the United States Patent and Trademark
Office, Patent Trial and Appeal Board in Nos. IPR2023-
00221, IPR2023-00254.
______________________
Decided: April 7, 2026
______________________
DAVID A. REED, Kilpatrick Townsend & Stockton LLP,
Atlanta, GA, argued for appellant. Also represented by
MICHAEL T. MORLOCK; JOHN C. ALEMANNI, CARL SANDERS,
Raleigh, NC.
FAHD H. PATEL, Office of the Solicitor, United States
Case: 24-2224 Document: 60 Page: 1 Filed: 04/07/2026

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MANUFACTURING RESOURCES INTERNATIONAL, INC. v. SQUIRES 2
Patent and Trademark Office, Alexandria, VA, argued for
intervenor. Also represented by NICHOLAS THEODORE
MATICH, IV, ROBERT J. MCMANUS, MICHAEL TYLER.
______________________
Before PROST, TARANTO, and STOLL, Circuit Judges.
STOLL, Circuit Judge.
Manufacturing Resources International, Inc. owns
U.S. Patent Nos. 10,506,740 and 11,013,142, which de-
scribe and claim cooling systems for electronic displays.
The patented cooling systems use two separate flow
paths—an open loop ambient air flow path and a closed
loop gas circulation path—and a common “heat exchanger.”
The closed loop path travels across the front of the display
and continues to the rear of the display where it may enter
the heat exchanger. Samsung Electronics Co., Ltd. and
Samsung Electronics America, Inc. successfully petitioned
for inter partes reviews of claims 1–3, 5–9, 11–13, 15–18,
and 20 of the ’740 patent and claims 1–15 of the ’142 pa-
tent on obviousness grounds. The Patent Trial and Appeal
Board construed “heat exchanger” to not require enclosed
channels or tubes and found that MRI’s objective evidence
of nonobviousness was entitled to little weight. As a result,
the Board held all challenged claims unpatentable. MRI
appeals, challenging the Board’s construction of “heat ex-
changer” and its findings that MRI’s objective evidence of
nonobviousness was entitled to little weight. We affirm.1
I
We first address MRI’s argument that the Board’s ob-
viousness determinations are based on an improper
1 Samsung notified us of its nonparticipation in the
case. The Director timely intervened pursuant to 35 U.S.C.
§ 143.
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MANUFACTURING RESOURCES INTERNATIONAL, INC. v. SQUIRES 3
construction of “heat exchanger.” Before the Board, the
parties did not dispute that a skilled artisan at the time of
the invention would have understood that a “heat ex-
changer” broadly includes many forms, including having
enclosed channels or tubes. MRI argued that the term
“heat exchanger,” as specifically used in the claims and pa-
tent specifications, however, requires “alternating, en-
closed channels or tubes of fluid.” J.A. 19 (citation
omitted). The Board disagreed, holding that a “heat ex-
changer may, but does not have to, include enclosed chan-
nels or tubes.” J.A. 33.
Claim construction is ultimately a question of law re-
viewed de novo. Intel Corp. v. Qualcomm Inc., 21 F.4th
801, 808 (Fed. Cir. 2021). “When construing claim terms,
we first look to, and primarily rely on, the intrinsic evi-
dence, including the claims themselves, the specification,
and the prosecution history of the patent . . . .” Sunovion
Pharms., Inc. v. Teva Pharms. USA, Inc., 731 F.3d 1271,
1276 (Fed. Cir. 2013) (first citing Phillips v. AWH Corp.,
415 F.3d 1303, 1315 (Fed. Cir. 2005) (en banc); and then
citing Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576,
1582 (Fed. Cir. 1996)). After reviewing the parties’ argu-
ments and the intrinsic evidence, we adopt the Board’s con-
struction of the term “heat exchanger.” First, the plain
language of the claims does not support MRI’s narrowing
construction. Claim 1 of the ’740 patent is representative
and the relevant limitation states: “a common heat ex-
changer located in the pathway of both the closed loop gas
circulation path and the open loop ambient air flow path.”
U.S. Patent No. 10,506,740 col. 9 ll. 61–63. Nothing in this
limitation or elsewhere in the claim limits the type of heat
exchanger required by the claim. The claim does not recite
that the heat exchanger has alternating enclosed channels
or tubes of fluid. Had MRI intended the claims to be lim-
ited to specific heat exchangers, it could have easily in-
cluded such language in the claims themselves. Instead,
the claims merely state where the heat exchanger is
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MANUFACTURING RESOURCES INTERNATIONAL, INC. v. SQUIRES 4
located and do not specify the structure of the heat ex-
changer.
Nor does the shared specification of the ’740 and
’142 patents limit the term “heat exchanger” to heat ex-
changers with enclosed channels or tubes.2 The Back-
ground section of the specification indicates that the prior
art used heat exchangers comprising fins. Id. at col. 2
ll. 1–2. Later, when describing the preferred embodiment,
the specification suggests the invention can work with
“heat exchangers” of all forms, stating that “many types of
heat exchangers are known and can be used with any of the
embodiments herein.” Id. at col. 4 ll. 20–22. While the
specification clearly discloses heat exchangers having al-
ternating, enclosed paths or tubes, it does not require such
structure. Instead, the specification states that the “heat
exchanger” of the invention: (1) “may be a cross-flow, par-
allel flow, or counter-flow heat exchanger;” (2) “would be
comprised of a plurality of stacked layers of thin plates;”
and (3) “[t]he plates may have a corrugated honeycomb, or
tubular design.” Id. at col. 4 ll. 22–25 (emphasis added).
Thus, the specification provides numerous examples of
heat exchangers and does not require or specify one partic-
ular type.
MRI argues that the shared “specification repeatedly,
consistently, and exclusively describes . . . a ‘heat ex-
changer’ with enclosed flow paths such as channels or
tubes.” Appellant’s Br. 32 (cleaned up). However, as ex-
plained above, the shared specification does not “repeat-
edly, consistently, and exclusively” describe a heat
exchanger with enclosed paths such as channels or tubes.
Moreover, generally, “[i]t is not enough for a patentee to
2 The ’740 and ’142 patents share a specification.
For simplicity, citations in this opinion will cite only to the
specification of the ’740 patent.
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MANUFACTURING RESOURCES INTERNATIONAL, INC. v. SQUIRES 5
simply disclose a single embodiment or use a word in the
same manner in all embodiments, the patentee must
‘clearly express an intent’ to redefine the term.” Thorner
v. Sony Comput. Ent. Am. LLC, 669 F.3d 1362, 1365
(Fed. Cir. 2012) (citations omitted). Here, if MRI wanted
to limit the claimed “heat exchanger” to “enclosed flow
paths such as channels or tubes,” it should have defined a
“heat exchanger” as requiring these features.
Lastly, the prosecution history does not inform the pub-
lic that the claimed “heat exchanger” must include alter-
nating enclosed channels or tubes of fluid. MRI argues that
two provisional applications in the chain of priority support
its position.3 First, MRI contends that we should adopt
MRI’s construction because the earlier provisional applica-
tion, the ’064 provisional, refers to a fin and not a heat ex-
changer, while the second provisional application, the
’736 provisional, refers to a heat exchanger and discloses
enclosed tubes and channels. Appellant’s Br. 34–35. MRI
argues that this shows that the inventor intended to dis-
tinguish between devices with fins and heat exchangers.
Appellant’s Br. 34. We are not convinced because it is not
clear from either this sequence or the specifications of the
provisional applications that this is necessarily so. MRI’s
other argument—relying on the specification of the
’736 provisional—fares no better than the similar argu-
ment it makes above with respect to the shared specifica-
tion.
3 Both the ’740 and ’142 patents claim priority from
U.S. Provisional Application Nos. 61/033,064 (the
“’064 provisional”) and 61/138,736 (the “’736 provisional”).
’740 patent col. 1 ll. 13–28; U.S. Patent No. 11,013,142
col. 1 ll. 19–33.
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MANUFACTURING RESOURCES INTERNATIONAL, INC. v. SQUIRES 6
We conclude that the Board did not err in concluding
that a heat exchanger may, but does not have to, include
enclosed channels or tubes.
II
MRI challenges the Board’s conclusion that the objec-
tive evidence of nonobviousness that MRI proffered is ac-
corded “little to no weight.” Appellant’s Br. 44 (citations
omitted). MRI offers the same arguments that this court
considered and rejected in Manufacturing Resources Inter-
national, Inc. v. Squires, No. 2024-2228, 2026 WL 879712
(Fed. Cir. Mar. 31, 2026). After considering MRI’s argu-
ments and the record on appeal, we see no error in the
Board’s analysis for the same reasons as in Manufacturing
Resources International, 2026 WL 879712.
III
We have considered MRI’s remaining arguments and
find them unpersuasive. For the foregoing reasons, we af-
firm the Board’s decision that the challenged claims of the
’740 and ’142 patents would have been obvious.
AFFIRMED
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