DCT

1:22-cv-00061

ABC IP LLC v. Big Daddy Enterprises Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-00061, N.D. Fla., 03/08/2022
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Florida on the basis that the Defendants reside in the district and/or have a regular and established place of business there.
  • Core Dispute: Plaintiffs allege that Defendants’ "ALAMO-15" trigger assembly for AR-pattern firearms infringes a patent related to a forced-reset trigger mechanism.
  • Technical Context: The technology concerns firearm trigger mechanisms designed to increase the rate of semiautomatic fire by using the firearm's own mechanical cycle to forcibly reset the trigger after each shot.
  • Key Procedural History: The complaint alleges that on December 17, 2021, in a separate court case between the parties (Case No. 1:21-cv-149, N.D. Fla.), Plaintiffs’ counsel expressly accused a preproduction model of the infringing device of infringing the patent-in-suit. This event occurred before Defendants allegedly began selling the accused product.

Case Timeline

Date Event
2017-09-29 U.S. Patent No. 10,514,223 Priority Date
2019-12-24 U.S. Patent No. 10,514,223 Issued
2020-12 Plaintiff's FRT-15 trigger first introduced to market
2021-12-17 Plaintiffs allegedly inform Defendants of infringement of a preproduction model
2022-02-25 Defendants allegedly begin offering the accused "PBG ALAMO-15" trigger for sale
2022-03-08 Complaint Filed

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

U.S. Patent No. 10,514,223 - "Firearm trigger mechanism," issued December 24, 2019

The Invention Explained

  • Problem Addressed: The patent background describes conventional semiautomatic triggers, which require the user to manually release and reset the trigger between shots. This limits the rate of fire. It also notes that prior art methods to increase firing speed, such as "bump firing" or triggers reset by the firearm's bolt, were either unreliable, complex, or not easily adaptable as "drop-in" solutions for popular firearm platforms like the AR-15 (Compl. ¶31-38; ’223 Patent, col. 1:22-34, col. 2:17-29).
  • The Patented Solution: The invention is a trigger mechanism where the hammer, as it is being cocked by the rearward movement of the firearm's bolt carrier, makes contact with the trigger member and forcibly pushes it back to the reset position. A "locking bar" simultaneously prevents the trigger from being pulled again until the bolt carrier has returned to its forward, "in-battery" position, ensuring the firearm can only fire one round per pull of the trigger (Compl. ¶39, ¶44; ’223 Patent, Abstract). This design eliminates the need for a traditional disconnector and allows for a significantly increased rate of semiautomatic fire using a drop-in assembly (Compl. ¶37; ’223 Patent, col. 2:35-49).
  • Technical Importance: The invention claims to provide a reliable, mechanical method for achieving a rapid rate of semiautomatic fire through a "drop-in" module that can be retrofitted into existing, popular firearm platforms without modifying other standard components like the bolt carrier (Compl. ¶29; ’223 Patent, col. 2:30-38).

Key Claims at a Glance

  • The complaint asserts independent Claim 4.
  • The essential elements of Claim 4 are:
    • A housing with openings for hammer and trigger assembly pins.
    • A hammer mounted in the housing to pivot between set and released positions.
    • A trigger member with a sear, mounted to pivot, and having a surface positioned to be contacted by the hammer during cycling, forcing the trigger member to the set position.
    • A locking bar, pivotally mounted and spring-biased, that mechanically blocks the trigger member from moving to the released position.
    • The locking bar is movable to a second, un-blocking position when contacted by the bolt carrier as it reaches a "substantially in-battery position," allowing the trigger to be pulled again.
  • The complaint reserves the right to assert other claims (Compl. ¶63).

III. The Accused Instrumentality

Product Identification

  • The "ALAMO-15" trigger, also referred to as the "PBG ALAMO-15" (Compl. ¶19, ¶48).

Functionality and Market Context

  • The complaint alleges the ALAMO-15 is a "drop-in" replacement trigger assembly for AR-pattern firearms (Compl. ¶48). The complaint provides a photograph of the accused device, showing its external housing and trigger shoe (Compl. ¶48).
  • It is alleged to operate by using contact from the firearm's hammer to forcibly reset the trigger, in combination with a locking bar that prevents the trigger from being pulled again until the bolt carrier returns to battery (Compl. ¶27, ¶50). The complaint further alleges that the ALAMO-15 uses a "roller on the locking bar," but contends this modification does not exclude it from the scope of the patent's claims (Compl. ¶28).
  • The complaint alleges that sales of the ALAMO-15 directly compete with and displace sales of Plaintiffs' patented FRT-15™ trigger (Compl. ¶68).

IV. Analysis of Infringement Allegations

’223 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
For a firearm having a receiver with a fire control mechanism pocket, assembly pin openings in side walls of the pocket, and a bolt carrier that reciprocates and pivotally displaces a hammer when cycled, a trigger mechanism, comprising: The ALAMO-15 is a trigger mechanism for an AR-pattern firearm, which has the specified receiver and a reciprocating bolt carrier. ¶64 (p. 19-20) col. 5:56-61
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins; The ALAMO-15 includes a housing with the claimed openings. The complaint provides an image of the accused housing with arrows pointing to the "Transversly alighed pairs of openings" (Compl. ¶64, p. 21). ¶64 (p. 21) col. 6:61-63
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions; The ALAMO-15 includes a hammer with a sear notch that pivots on a transverse axis. The complaint includes annotated diagrams of the accused hammer in its "SET POSITION" (Compl. ¶64, p. 22). ¶64 (p. 21-22) col. 6:64-67
a trigger member having a sear and mounted in the housing to pivot on a transverse axis...the trigger member having a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position; The ALAMO-15 trigger member allegedly has a surface that is contacted by the hammer during cycling, which forces the trigger to its set position. A diagram shows this "Surface contacted by hammer" in an assembled view of the accused device (Compl. ¶64, p. 24). ¶64 (p. 23-24) col. 7:1-5
a locking bar pivotally mounted in the housing and spring biased toward a first position in which the locking bar mechanically blocks the trigger member from moving to the released position, The ALAMO-15 includes a spring-biased, pivoting locking bar that allegedly blocks the trigger member. An annotated diagram shows the components of the accused locking bar mechanism in its "FIRST POSITION" (Compl. ¶64, p. 25). ¶64 (p. 24-25) col. 7:6-9
and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved by an external force to the released position. The locking bar is allegedly moved to a second, un-blocking position by the bolt carrier when it is in battery, allowing the trigger to be pulled. A close-up photograph shows the alleged interaction between the bolt carrier and the locking bar in the accused device (Compl. ¶64, p. 27). ¶64 (p. 26-27) col. 7:9-14

Identified Points of Contention

  • Technical Question: The complaint preemptively addresses the fact that the accused device "uses a roller on the locking bar" (Compl. ¶28). A primary technical question will be whether this roller fundamentally alters the operation of the locking bar such that it no longer meets the functional requirements of the claim. The complaint argues that because the claims use the open-ended term "comprising," the addition of a roller wheel does not avoid infringement (Compl. ¶66).
  • Scope Question: The analysis may focus on whether the phrase "contacted by the bolt carrier" requires direct physical contact between the bolt carrier and the main body of the locking bar, as depicted in the patent's figures ('223 Patent, Fig. 3), or if it can be read to cover indirect contact mediated by an added component like a roller.

V. Key Claim Terms for Construction

  • The Term: "locking bar"
  • Context and Importance: The locking bar is a critical component that ensures the trigger mechanism remains semiautomatic and prevents "hammer follow." Its interactions with the trigger member and the bolt carrier are central to the invention's function. Practitioners may focus on this term because the accused device allegedly adds a "roller" to it, raising the question of whether the modified component still falls within the claim's scope (Compl. ¶28).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 4 defines the locking bar functionally: it is "pivotally mounted," "spring biased," "mechanically blocks the trigger member," and is "movable... when contacted by the bolt carrier." A party could argue that as long as the accused component performs these functions, it is a "locking bar," regardless of whether it incorporates an additional feature like a roller to facilitate contact. The use of "comprising" in the claim preamble may support this view (Compl. ¶66).
    • Evidence for a Narrower Interpretation: The detailed description and figures show direct contact between the "engagement surface 54" of the bolt carrier and the "upper end of the locking bar 62" ('223 Patent, col. 4:55-57; col. 5:1-6; Fig. 3). A party could argue that the claims, when read in light of the specification, require this direct interaction and that mediating the contact with a roller is a different, non-infringing mechanism.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement. It points to promotional videos and websites (e.g., GRAVESTRIGGERBDU.COM) that allegedly instruct customers on how to purchase and, by extension, use the accused ALAMO-15 trigger (Compl. ¶57-60). The complaint alleges Defendants' actions "caus[e] to be used without authority" the patented technology (Compl. ¶63).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It specifically pleads that on December 17, 2021, in open court during a prior litigation, Plaintiffs' counsel "expressly accused" a preproduction model of the ALAMO-15 of infringing the ’223 Patent. The complaint alleges Defendants then began selling the accused product commercially on February 25, 2022, in "defiance" of this express accusation (Compl. ¶18, ¶19, ¶56).

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

The resolution of this case may turn on two central questions:

  1. A core issue will be one of claim scope and the doctrine of equivalents: does the term "locking bar... contacted by the bolt carrier" read on the accused device's locking bar, which allegedly uses a roller to mediate this contact? The court will need to determine if this modification is merely an additional, non-substantive feature, as Plaintiffs argue, or if it constitutes a functionally different and non-infringing design.

  2. A key factual question will be one of intent: did the Defendants’ alleged launch of the ALAMO-15 after being put on notice of infringement in a prior court proceeding constitute willful infringement? The specific content and context of the alleged December 17, 2021 accusation will be critical evidence in assessing the egregiousness of Defendants' alleged conduct.