Dometic Corp. v. ITC — Federal Circuit Affirms ITC Refusal to Block Import of Marine Air Conditioning Products

Background

Dometic Corp. and Dometic Sweden AB held U.S. Patent No. 8,056,351, which describes a marine air conditioning system designed for easy installation in tight and confined spaces on boats. In November 2022, Dometic filed a complaint with the International Trade Commission alleging that importation and sale of certain marine air conditioning systems by Citimarine, L.L.C., Mabru Power Systems, Inc., Shanghai Hopewell Industrial Co. Ltd., and Shanghai Hehe Industrial Co. Ltd. infringed claims 1 through 2, 4 through 5, 7, and 18 through 22 of the patent. The ITC found no violation of Section 337, concluding that certain claims were anticipated by prior art and the accused products did not infringe the remaining claims. Dometic appealed.

Court’s Holding

Writing for the Federal Circuit, Judge Taranto affirmed the ITC’s determination. The court found that the ITC properly concluded that the Vector Compact product anticipates several of the asserted claims. The decision involved disputes about claim interpretation, particularly regarding the term “assembly” and its relationship to the “main body” of the air conditioning system. The Federal Circuit agreed with the ITC’s construction and found no error in its determination that the remaining claims were not infringed by the accused products. As a result, Dometic was denied the exclusion order it sought to block importation of the competing products.

Key Takeaways

• Patent holders seeking ITC exclusion orders must ensure their claims can withstand both invalidity and non-infringement defenses, as the ITC examines both in Section 337 investigations.
• Claim construction remains the critical battleground in ITC patent disputes; how terms like “assembly” are defined can determine whether prior art anticipates the claims.
• The case demonstrates that even patents directed to specialized mechanical designs in niche markets face rigorous prior art challenges at the ITC.

Why It Matters

This case is a reminder that the ITC is not a rubber stamp for exclusion orders. Companies seeking to block competing imports through Section 337 investigations must carefully assess both the validity and scope of their patent claims before filing. For importers and competitors, the decision shows that vigorous prior art searches and non-infringement arguments remain effective defenses in ITC proceedings, even when the patent holder is a well-established market participant.