ABC IP LLC v. SGC LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers Inc. (Texas)
  • Defendant: SGC, LLC, d/b/a Scottsdale Gun Club (Arizona), Terence Schmidt (individual), and Ronald Kennedy (individual)
  • Plaintiff’s Counsel: Wood Herron & Evans, LLP
• Case Identification: 2:26-cv-00085, D. Ariz., 01/13/2026
• Venue Allegations: Venue is alleged to be proper in the District of Arizona because Defendants reside in the district, maintain a regular and established place of business in the district, and have allegedly committed acts of infringement there.
• Core Dispute: Plaintiffs allege that Defendants’ "Partisan Disruptor" firearm trigger infringes four patents related to forced reset trigger mechanisms for semi-automatic firearms.
• Technical Context: The technology at issue involves firearm trigger mechanisms that use the reciprocating motion of the firearm's bolt carrier to mechanically reset the trigger, a design that can enable a higher rate of fire than conventional semi-automatic systems.
• Key Procedural History: The complaint alleges that the manufacturer of the accused device maintains a "Legal Library" on its website that includes copies of the asserted patents, which Plaintiffs use as a basis to allege that Defendants had knowledge of the patents and that any infringement was willful.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,514,223 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 10,514,223, “Firearm Trigger Mechanism,” issued December 24, 2019. (Compl. ¶12).

The Invention Explained

• Problem Addressed: The patent’s background section describes the desire among firearm users to increase the rate of semi-automatic fire. (Compl. ¶21; ’223 Patent, col. 1:36-39). It notes that standard semi-automatic triggers, which require a user to consciously release the trigger to allow it to reset, limit this rate, and that alternative methods like "bump firing" require practice or specialized equipment. (’223 Patent, col. 1:12-29, 40-54).
• The Patented Solution: The invention provides a trigger mechanism where the hammer, as it is pushed rearward by the cycling bolt carrier, makes physical contact with the trigger member, forcing it back to the reset position. (’223 Patent, col. 2:40-44). A separate, pivotally mounted "locking bar" then blocks the trigger from being pulled again until the bolt carrier has returned to its "substantially in-battery position," which is intended to prevent premature firing or "hammer follow." (’223 Patent, Abstract; col. 2:41-48).
• Technical Importance: This design offers a "drop-in" replacement module for popular firearm platforms that can increase the potential rate of fire without requiring modification of other standard components like the bolt carrier. (’223 Patent, col. 2:21-29).

Key Claims at a Glance

• The complaint asserts independent Claim 4. (Compl. ¶37).
• The essential elements of Claim 4 include:
  • A housing with openings for hammer and trigger pins.
  • A hammer with a sear notch mounted in the housing.
  • A trigger member with a sear and a surface positioned to be contacted by the hammer during cycling, with this contact causing the trigger member to be forced to its set position.
  • A locking bar pivotally mounted in the housing, spring-biased to a first position where it mechanically blocks the trigger member, and movable to a second position (allowing the trigger to be pulled) when contacted by the bolt carrier as it reaches a "substantially in-battery position."

U.S. Patent No. 11,724,003 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 11,724,003, “Firearm Trigger Mechanism,” issued August 15, 2023. (Compl. ¶13).

The Invention Explained

• Problem Addressed: While forced reset triggers can increase the rate of fire, users may also desire the functionality of a standard semi-automatic trigger within the same firearm without changing parts. (Compl. ¶24). The patent background notes that "further improvement in forced reset triggers is desired." (’003 Patent, col. 2:21-22).
• The Patented Solution: The invention adds a multi-position safety selector to the forced reset trigger design. This selector allows the user to choose between: 1) a standard semi-automatic mode where a disconnector operates conventionally to catch the hammer, and 2) a forced reset mode where the safety selector physically prevents the disconnector from engaging the hammer, thereby enabling the forced reset functionality described in the ’223 Patent. (Compl. ¶24; ’003 Patent, Abstract).
• Technical Importance: This approach provides a user-selectable, dual-mode functionality, combining a conventional trigger operation and a rapid-fire, forced-reset capability in a single "drop-in" unit. (Compl. ¶24).

Key Claims at a Glance

• The complaint asserts independent Claim 4. (Compl. ¶45).
• The essential elements of Claim 4 include:
  • A housing, hammer, trigger member, disconnector, and locking member, largely similar to the components of the ’223 Patent.
  • A safety selector adapted to pivot between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • A functional element describing that in the "standard semi-automatic position," the disconnector hook catches the hammer hook.
  • A functional element describing that in the "forced reset semi-automatic position," the rearward movement of the bolt carrier forces the trigger to its set position, and the "safety selector prevent[s] said disconnector hook from catching said hammer hook."

U.S. Patent No. 12,036,336 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024. (Compl. ¶14).
• Technology Synopsis: This patent describes a trigger mechanism featuring a safety selector that enables switching between a standard semi-automatic mode and a forced reset semi-automatic mode. In the forced reset mode, the safety selector repositions the disconnector to prevent it from catching the hammer, allowing the cycling of the bolt carrier to reset the trigger. (Compl. ¶24; ’336 Patent, Abstract).
• Asserted Claims: Independent Claim 3. (Compl. ¶52).
• Accused Features: The complaint alleges that the "Partisan Disruptor" trigger's three-position selector and its ability to operate in both a standard mode and a forced reset mode infringe this patent. (Compl. ¶30, 53).

U.S. Patent No. 12,274,807 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025. (Compl. ¶15).
• Technology Synopsis: This patent claims a trigger mechanism that includes a hammer, trigger, disconnector, locking member, and a three-position safety selector. The selector is designed to switch the mechanism between a standard semi-automatic operation, where the disconnector engages the hammer, and a forced reset operation, where the disconnector is prevented from engaging the hammer. (Compl. ¶24; ’807 Patent, Abstract).
• Asserted Claims: Independent Claim 1. (Compl. ¶59).
• Accused Features: The infringement allegation targets the overall structure and selectable functionality of the "Partisan Disruptor," specifically its use of a three-position selector to switch between standard and forced reset modes of operation. (Compl. ¶30, 60).

III. The Accused Instrumentality

Product Identification

• The (3-Position) “Partisan Disruptor” trigger. (Compl. ¶26).

Functionality and Market Context

• The complaint describes the accused product as a "drop-in" trigger mechanism for AR-pattern firearms that can be sold as a standalone component or pre-installed in a receiver or complete firearm. (Compl. ¶28). Its key accused functionality is its ability to operate in three modes selected by the user: "safe, standard semiautomatic with disconnector, and forced reset semiautomatic." (Compl. ¶30). The complaint alleges that Defendants sell or offer for sale the accused device through at least two websites. (Compl. ¶27). A screenshot from the Scottsdale Gun Club website shows the accused product, an assembled trigger mechanism, listed for sale. (Compl. p. 7).

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,514,223 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The definition of "substantially in-battery position" may be a point of dispute. This is a term of degree that is critical to the safety function of the locking bar, and the parties may contest the precise point in the bolt carrier's travel at which the locking bar is claimed to disengage.
  • Technical Questions: A key technical question is whether the accused product's locking bar "mechanically blocks the trigger member" in the manner required by the claim. The complaint’s allegations are supported by photographs, and a factual dispute may arise over the precise nature and timing of the interaction between the accused locking bar and trigger member during operation.

U.S. Patent No. 11,724,003 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The claim requires the safety selector to "prevent" the disconnector from catching the hammer. The scope of "preventing" could be a central issue—whether it is limited to the specific mechanism disclosed in the specification (e.g., blocking the disconnector's pivot) or covers any method by which the selector achieves this outcome.
  • Technical Questions: The primary technical question will be how the accused product's safety selector interacts with its disconnector. The complaint alleges the selector performs the claimed "preventing" function, but the litigation will likely require a detailed mechanical analysis of whether the accused components interact in the same way as the claimed invention to achieve the forced reset mode.

V. Key Claim Terms for Construction

• Term: "mechanically blocks" (from ’223 Patent, Claim 4)

  • Context and Importance: This term defines the function of the locking bar, a key safety feature of the invention. The infringement analysis for the ’223 Patent will turn on whether the accused device's locking bar performs an action that falls within the court's construction of this term.
  • Intrinsic Evidence for a Broader Interpretation: The patent states the bar is in a position "in which it blocks pivotal movement of the trigger 26." (’223 Patent, col. 5:39-41). This general functional language could support a construction that covers any physical impediment to the trigger's movement.
  • Intrinsic Evidence for a Narrower Interpretation: The detailed description and figures show a specific embodiment where the locking bar (62) engages a "second contact surface 32 of the trigger member 26." (’223 Patent, col. 5:58-61; Fig. 5). This could support a narrower construction limited to this specific point and type of interaction.

• Term: "preventing said disconnector hook from catching said hammer hook" (from ’003 Patent, Claim 4)

  • Context and Importance: This functional language describes the core innovation of the multi-mode trigger claimed in the ’003 Patent. The distinction between the standard and forced-reset modes hinges on whether the safety selector performs this "preventing" action. Practitioners may focus on this term because its construction will determine whether the accused product's mode-switching mechanism infringes.
  • Intrinsic Evidence for a Broader Interpretation: The claim uses the functional word "preventing" without specifying the mechanism. This could support a broad interpretation covering any action by the safety selector that results in the disconnector failing to engage the hammer.
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific mechanism: "a narrow semi-circular portion 116 permits the trigger blade 54 to be pulled but prevents the disconnector 60 from pivoting with the trigger member 38 thus preventing the disconnector hook 64 from catching the hammer hook." (’003 Patent, col. 9:24-29). This language could support a narrower construction limited to a method that involves stopping the disconnector's ability to pivot.

VI. Other Allegations

• Willful Infringement: The complaint alleges willful infringement for all four asserted patents. (Compl. ¶¶ 35, 42, 49, 56, 63). The basis for this allegation is Plaintiffs' claim that the manufacturer of the accused device, Partisan Triggers, maintains a webpage titled "FRT Legal Library" which links to copies of the ’223 and ’336 Patents. (Compl. ¶33). The complaint alleges this provides notice of Plaintiffs' patent rights to the manufacturer's "reseller customers," including the Defendants, and that the individual defendants had knowledge of these rights through the library. (Compl. ¶¶ 33-34).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of functional operation: does the accused Partisan Disruptor’s safety selector mechanism, when switched to its third position, perform the function of “preventing” the disconnector from engaging the hammer in a way that is covered by the claims of the ’003, ’336, and ’807 patents? The case will likely require a detailed mechanical comparison between the accused device and the patented embodiments.
• Another key question will be one of claim construction: can the term “mechanically blocks” from the ’223 Patent be interpreted broadly to cover any physical impediment by the locking bar, or will it be narrowed to the specific trigger-surface interaction shown in the patent's figures? The answer to this question may be dispositive of infringement for that patent.
• Finally, a key evidentiary question for willfulness will be whether the existence of a "Legal Library" on a third-party manufacturer's website is sufficient to establish that the reseller Defendants had the requisite knowledge of the asserted patents and infringement prior to the lawsuit.