IP Law Daily, PATENT—Fed. Cir.: Obviousness of convection cooling system for electronic displays affirmed, (Apr 1, 2026)

By Kevin M. Finson, J.D.

Claims relating to cooling displays using constricted air channels were invalid as obvious because two separate prior art references taught the claimed use of a plate immediately behind the display to constrict airflow for cooling.

A patentee failed to show any error in a Patent Trial and Appeal Board (PTAB) decision finding its cooling system unpatentable as obvious, the U.S. Court of Appeals for the Federal Circuit has held in a nonprecedential decision. The PTAB (board) had properly relied on the plain language of prior art references and expert testimony, which constituted substantial evidence (Manufacturing Resources International, Inc. v. Squires, No. 24-2228 (Fed. Cir. Mar. 31, 2026)).

Manufacturing Resources International, Inc. (MRI) was the owner of U.S. Patents No. 8,854,595 (the ’595 patent) and 9,173,322 (the ’322 patent), which shared a specification and were entitled “Constricted Convection Cooling System for an Electronic Display.” The patents were directed at improvements to systems for cooling displays, especially large displays exposed to sunlight, by directing airflow through narrow channels immediately behind the display surface using a constricted convection plate. Samsung Electronics Co. (Samsung) petitioned for inter partes review of several claims of both patents on the ground of obviousness. The PTAB found that the prior art disclosed the constricted convection plate, and that MRI’s objective-indicia evidence was entitled to little weight and held all challenged claims unpatentable. MRI appealed. Samsung withdrew from the appeal, and the Director of the USPTO intervened to defend the board’s decision.

Prior art teachings. MRI argued that the two prior art references relied upon by the board did not disclose a constricted convection plate. The court reviewed both prior art references and noted that the plain language, as well as supporting expert testimony, provided substantial evidence to support the board’s conclusion that both prior art references disclosed the convection plate at issue. The court also found no error in the board’s construction of the term “access apertures,” noting that there was no textual support for the narrow definition proposed by MRI.

Objective indicia. The PTAB had found that MRI failed to show a nexus between commercial success and the claimed invention. MRI had alleged in a conclusory fashion that certain commercially successful Samsung displays infringed the claims at issue but presented no evidence or analysis to show that the commercial success was attributable to the patented cooling system and not to other features of the displays. Allegations of copying through a tear-down of a device which practiced the patents were properly disregarded by the board because substantial evidence supported the board’s finding that Samsung’s products were designed prior to the tear-down.

The court affirmed the PTAB’s decision.

The Case is No. 24-2228.

Judge: Taranto, R.

Attorneys: John C. Alemanni (Kilpatrick Townsend & Stockton LLP) for Manufacturing Resources International, Inc. Fahd H. Patel, U.S. Patent and Trademark Office, for John A. Squires.

Companies: Manufacturing Resources International, Inc.

Cases: Patent USPTO FedCirNews