Dometic Corp. v. Itc

CourtCourt of Appeals for the Federal Circuit
DecidedApril 6, 2026
Docket24-1796
StatusUnpublished

This text of Dometic Corp. v. Itc (Dometic Corp. v. Itc) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dometic Corp. v. Itc, (Fed. Cir. 2026).

Opinion

Case: 24-1796 Document: 64 Page: 1 Filed: 04/06/2026

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________

DOMETIC CORP., DOMETIC SWEDEN AB, Appellants

v.

INTERNATIONAL TRADE COMMISSION, Appellee

CITIMARINE, L.L.C., MABRU POWER SYSTEMS, INC., SHANGHAI HOPEWELL INDUSTRIAL CO. LTD., SHANGHAI HEHE INDUSTRIAL CO. LTD., Intervenors ______________________

2024-1796 ______________________

Appeal from the United States International Trade Commission in Investigation No. 337-TA-1346. ______________________

Decided: April 6, 2026 ______________________

STEPHEN REID HOWE, Husch Blackwell LLP, Milwau- kee, WI, argued for appellants. Also represented by AVERY HITCHCOCK; KARA RENEE FUSSNER, St. Louis, MO; BEAU JACKSON, Kansas City, MO; MATTHEW KAMPS, Chicago, IL.

NAMO KIM, Office of the General Counsel, United Case: 24-1796 Document: 64 Page: 2 Filed: 04/06/2026

States International Trade Commission, Washington, DC, argued for appellee. Also represented by AMANDA PITCHER FISHEROW.

PAUL M. BARTKOWSKI, Bartkowski PLLC, McLean, VA, argued for all intervenors. Also represented by THOMAS RICHARD BURNS, JR. Intervenor Mabru Power Systems, Inc. also represented by MARK D. BOWEN, Malin Haley Di- Maggio & Bowen, PA, Fort Lauderdale, FL. Intervenors Shanghai Hopewell Industrial Co. Ltd. and Shanghai Hehe Industrial Co. Ltd. also represented by JASON XU, Rimon, P.C., Washington, DC. ______________________

Before TARANTO, CLEVENGER, and STOLL, Circuit Judges. TARANTO, Circuit Judge. Dometic Corp. and Dometic Sweden AB (together, Dometic) filed a complaint with the International Trade Commission against Citimarine, L.L.C., Mabru Power Sys- tems, Inc., Shanghai Hopewell Industrial Co. Ltd., and Shanghai Hehe Industrial Co. Ltd. (collectively, Citima- rine), seeking an order to block importation of certain prod- ucts under section 337 of the Tariff Act of 1930, as amended, 19 U.S.C. § 1337. Dometic asserted, as now rel- evant, that the products infringe claims 1–2, 4–5, 7, and 18–22 of its U.S. Patent No. 8,056,351, whose subject is an air conditioning device for nautical vehicles. The Commis- sion denied relief to Dometic on claims 1–2, 4–5, and 7 on the ground that those claims are invalid for anticipation. The Commission denied relief to Dometic on claims 18–22 on two related grounds—that the accused imported prod- ucts do not infringe those claims and that the domestic products asserted to meet section 337’s domestic-industry requirement do not come within the claims. We now af- firm. Case: 24-1796 Document: 64 Page: 3 Filed: 04/06/2026

DOMETIC CORP. v. ITC 3

I A The ’351 patent addresses the problem of providing easily installable marine air conditioners in a confined and tightly packed space. ’351 patent, col. 1, lines 19–27. It describes a device with a main body, blower, and assembly with certain components and rotational properties. Id., col. 1, lines 35–42. The main body consists of a drain pan and the features mounted above the drain pan, in which the evaporator occupies a mounting area above it. Id., col. 4, lines 1–7; id., col. 9, lines 58–65; id., col. 11, lines 24–26. The blower includes a fan for moving air into and out of the air conditioner system. Id., col. 1, lines 37–39; id., col. 11, lines 26–31. The assembly includes a guiding cover and a cylindrical duct element to facilitate the flow of air between the main body and blower, where the guiding cover is a cover-like element that is on top of the evaporator. Id., col. 1, lines 38–39, 50–53; id., col. 9, line 66, through col. 10, line 2. Independent claim 1 reads as follows: 1. An air conditioning device for a nautical vehicle including: a main body; and a blower including an inlet and an outlet, the inlet being in an air communication with the main body, the blower further in- cluding blades rotating therewithin about a first axis, and an assembly for adjusting the blower with respect to the main body about a second axis so as to alter an orienta- tion of the outlet, the assembly including a guiding cover and a cylindrical duct el- ement for maintaining the main body and Case: 24-1796 Document: 64 Page: 4 Filed: 04/06/2026

the blower at the second base, the first base of the duct element dimensioned to corre- spondingly fit the guiding cover, and the duct element being rotatably adjustable around the guiding cover about the second axis at the first base so as to alter the ori- entation of the outlet. Id., col. 12, line 52, through col. 13, line 3 (emphases added). As the emphases indicate, the claim recites the above-described components and two axes—one around which the fan blades inside the blower rotate, the other around which the blower as a whole can rotate, vis-à-vis the main body, to change the direction of the blower’s out- let. See id., col. 1, lines 39–42; id., col. 2, lines 47–50; id., col. 11, line 26, through col. 12, line 3. Independent claim 18 reads as follows: 18. An air conditioning device for a nautical vehicle including: a main body; and a blower including an inlet and an outlet, the inlet being in an air communication with the main body, the blower being ro- tatable about [a] first axis so that the outlet can be oriented toward a first direct[i]on and a second direction, and the first and second directions point to substantially different lateral sides of the main body, and an assembly for adjusting the blower with respect to the main body about a second axis so as to alter an orienta- tion of the outlet, the assembly including a guiding cover and a cyli[n]drical duct ele- ment for maintaining the main body and the blower and the blower in air Case: 24-1796 Document: 64 Page: 5 Filed: 04/06/2026

DOMETIC CORP. v. ITC 5

communication with one another, the duct element having a first base and a second base, coupled to the blower at the duct ele- ment dimensioned to correspondingly fit the guiding cover, and the duct element being rotat[a]bly adjustable around the guiding cover about the second axis at the first base so as to alter the ori- entation of the outlet. Id., col. 14, lines 4–20 (emphases added). As the emphases indicate, this claim recites two axes, but neither is defined as the axis of the fan blades’ rotation inside the blower (un- like an axis in claim 1). Cf. id., col. 1, lines 39–40; id., col. 12, lines 16–19. Instead, both axes in claim 18 are for changing the direction of the blower outlet. One is identi- fied simply as an axis for rotating the blower to do so. See id., col. 3, lines 1–4. The second is also an axis for adjusting the orientation of the blower but is identified as doing so by rotating the duct element of the assembly (attached to the blower) around the guiding cover. See id., col. 1, lines 56– 58; id., col. 11, lines 17–18. B In November 2022, Dometic filed its complaint, accus- ing Citimarine of violating section 337(a)(1)(B) of the Tariff Act of 1930, 19 U.S.C. § 1337(a)(1)(B), by importing and then selling units of certain marine air conditioning sys- tems that, Dometic asserted, infringe the ’351 patent. J.A. 268–94. The Commission instituted an investigation based on the complaint the next month. Certain Marine Air Con- ditioning Systems, Components Thereof, and Products Con- taining the Same; Institution of Investigation, 87 Fed. Reg. 76216, 76216–17 (Dec. 13, 2022) (Institution). The accused products, as well as the domestic-industry articles pro- tected by the patent, see 19 U.S.C. § 1337

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