Rare Breed Triggers Inc v. Big Daddy Enterprises Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Rare Breed Triggers, Inc. (Texas)
  • Defendant: Big Daddy Enterprises, Inc. (Florida), and numerous other corporate and individual defendants (Florida, New Mexico, Idaho, California)
  • Plaintiff’s Counsel: Dhillon Law Group, Inc.; Wood Herron & Evans LLP
• Case Identification: 1:25-cv-00181, N.D. Fla., 07/01/2025
• Venue Allegations: Venue is alleged to be proper based on a forum selection clause in a prior settlement agreement between the parties and because a substantial portion of the events giving rise to the claims occurred in the district.
• Core Dispute: Plaintiff alleges that Defendants breached a patent litigation settlement agreement and violated a permanent injunction by continuing to manufacture, market, and sell firearm triggers that infringe a patent related to Forced Reset Trigger technology.
• Technical Context: The technology at issue involves "forced reset triggers" (FRTs) for semi-automatic firearms, which use the energy from the firearm's cycling action to mechanically reset the trigger, enabling a faster rate of fire than conventional trigger mechanisms.
• Key Procedural History: This lawsuit follows prior patent infringement litigation between the parties (Case Nos. 1:21-cv-00149 and 1:22-cv-00061). That litigation resulted in a September 2022 Settlement Agreement and an October 19, 2022, Permanent Injunction, in which the original defendants ("Settling Defendants") stipulated to the validity, enforceability, and infringement of U.S. Patent No. 10,514,223 by their "Wide Open Trigger" and "Alamo-15" products. The current complaint alleges Defendants have violated that agreement and injunction by selling infringing FRTs through new corporate entities and websites.

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 Issue Date
2021-09-15	Plaintiff files first patent infringement action
2021-12-30	Preliminary injunction entered in prior litigation
2022-03-08	Plaintiff files related infringement action
2022-09-21	Defendant McKnight orally assures Plaintiff of intent to cease FRT sales
2022-10-19	Court enters Consent Judgment and Permanent Injunction
2025-05-19	Defendant Atrius allegedly launches website for direct sales of accused FRTs
2025-07-01	Complaint Filing Date

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

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

The Invention Explained

• Problem Addressed: The patent’s background section notes that shooters often desire to increase the rate of semi-automatic fire, but methods like "bump firing" can be imprecise, and existing trigger modification devices are often complex, expensive, or require significant firearm modification beyond a simple "drop-in" installation (’223 Patent, col. 1:36-51, col. 2:10-17).
• The Patented Solution: The invention is a trigger mechanism where the standard rearward motion of the bolt carrier during the firing cycle resets the hammer. Crucially, the resetting hammer then makes physical contact with a surface on the trigger member, mechanically forcing the trigger itself forward into its reset position. This eliminates the need for the shooter to consciously release the trigger between shots. The mechanism also includes a "locking bar" that prevents the trigger from being pulled again until the bolt carrier is safely back in its forward, "in-battery" position, preventing malfunctions like "hammer follow" (’223 Patent, Abstract; col. 2:30-49). This interaction is depicted in Figure 5, showing the bolt carrier (52) pushing the hammer (18), which in turn contacts the trigger member (26) to force a reset.
• Technical Importance: The patented solution provides a self-contained, "drop-in" module that can increase the cyclic rate of fire for common platforms like AR-pattern firearms without requiring modification to other key components like the bolt carrier assembly (’223 Patent, col. 2:30-38).

Key Claims at a Glance

While the complaint is for breach of contract, the underlying dispute concerns technology covered by the ’223 Patent. The core invention is captured in independent claim 1.

• Asserted Independent Claim: Claim 1.
• Essential Elements of Claim 1:
  • A hammer with a sear notch mounted to pivot between set and released positions.
  • A trigger member with a sear mounted to pivot between set and released positions.
  • The trigger member has a surface positioned to be contacted by the hammer as the hammer is displaced by the cycling bolt carrier, where this contact forces the trigger member to its set position.
  • A pivotally mounted, spring-biased locking bar that mechanically blocks the trigger member from moving to the released position.
  • The locking bar is movable out of its blocking position when contacted by the bolt carrier as it reaches a substantially in-battery position, thereby allowing the trigger to be moved.
• The complaint does not assert specific claims, as the prior settlement stipulated that the original products infringed "one or more claims" of the ’223 Patent (Compl. ¶40).

III. The Accused Instrumentality

Product Identification

The complaint names a series of firearm triggers, including the "WOT Trigger," "Selektor Trigger," "Super Selektor," "Super Safety AR-15 Trigger," and the "Atrius Select-Fire Assisted Reset Trigger" (Compl. ¶7, ¶53).

Functionality and Market Context

• The complaint alleges that all accused products are "Forced Reset Triggers" or "FRTs" that operate under the principle defined in the parties' Settlement Agreement: "any fire control group where movement of the action causes the trigger member to be forced to the fully reset position" (Compl. ¶2, ¶45.b). Specifically, the "Atrius Select-Fire Assisted Reset Trigger" was marketed with the feature of "elimination of trigger reset," which the complaint alleges "directly replicates the patented functionality" (Compl. ¶62). No probative visual evidence provided in complaint.
• Plaintiff alleges these infringing activities have generated substantial revenue, claiming that Defendant Atrius alone fulfilled approximately 9,000 orders worth around $1.79 million in a two-week period after launching its website (Compl. ¶64, ¶122).

IV. Analysis of Infringement Allegations

The complaint alleges breach of a settlement agreement that was predicated on infringement of the ’223 Patent. The following chart summarizes how the newly accused products are alleged to function in a manner that would infringe the representative independent claim of the patent.

’223 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a trigger member having a surface positioned to be contacted by the hammer when the hammer is displaced by cycling of the bolt carrier...	The accused products are all alleged to be "Forced Reset Triggers" where the movement of the firearm's action forces the trigger to reset (Compl. ¶2, ¶112).	¶2, ¶112	col. 5:31-37
...the contact causing the trigger member to be forced to the set position;	The "Atrius" trigger is specifically advertised as providing an "elimination of trigger reset," which the complaint alleges is a direct replication of the patented function (Compl. ¶62).	¶62	col. 5:31-37
a locking bar pivotally mounted... [that] mechanically blocks the trigger member from moving to the released position...	The complaint alleges the new products are "substantially identical" or "functionally identical" to previously enjoined products, which were found to infringe the ’223 Patent (Compl. ¶80, ¶128).	¶80, ¶128	col. 5:37-46
...and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position...	The complaint's theory rests on the new products being, at most, colorable variations of the original products that were stipulated to infringe all elements of one or more claims (Compl. ¶45.a).	¶45, ¶80	col. 5:56-65

Identified Points of Contention

• Scope Questions: A central issue may be whether the newly accused triggers, sold under different names (e.g., "Atrius Select-Fire"), fall within the Settlement Agreement's definition of a "Forced Reset Trigger" (Compl. ¶45.b). This inquiry will likely depend on whether their mechanism of action meets the limitations of the ’223 Patent’s claims.
• Technical Questions: The case raises the factual question of whether the internal mechanics of the new triggers are "substantially identical" or "functionally identical" to the designs previously adjudicated as infringing (Compl. ¶80-81). Discovery will likely focus on the precise method by which the new triggers achieve reset and whether a component performs the function of the claimed "locking bar."

V. Key Claim Terms for Construction

• The Term: "a surface positioned to be contacted by the hammer" (Claim 1)

• Context and Importance: This phrase defines the core inventive concept of the patent—the mechanical trigger reset initiated by the hammer. The infringement analysis for the newly accused products will turn on whether they incorporate a structure that performs this specific function, regardless of its exact form. Practitioners may focus on this term because it distinguishes the invention from standard triggers where reset is passive.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language uses the general term "a surface," which is not limited to a specific shape or component part. The specification describes the function: "contact between a rear surface ... of the hammer ... and a contact surface ... of the trigger member ... forces the trigger to pivot" (’223 Patent, col. 5:31-37). This functional description could support a broad reading covering any point of contact on the trigger that achieves this result.
  • Evidence for a Narrower Interpretation: The figures and detailed description show a specific embodiment where the "contact surfaces (30, 32) may be integral to a specially formed trigger body or may be a separate insert" that mates with the trigger (’223 Patent, col. 4:6-11; Figs. 2, 5). A party could argue the term should be construed more narrowly in light of this specific disclosed structure.

• The Term: "locking bar" (Claim 1)

• Context and Importance: This element is a key safety and operational feature, preventing out-of-battery firing ("hammer follow"). The analysis will question whether the accused devices contain a part that meets the functional requirements of being a "locking bar" as claimed, namely blocking the trigger and being un-blocked by the bolt carrier's return to battery.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "locking bar" is not explicitly defined. The claim defines it functionally: it "mechanically blocks the trigger member" and is "movable ... when contacted by the bolt carrier" (’223 Patent, Claim 1). Any component that performs these two functions, regardless of name or shape, could fall within the scope of the term.
  • Evidence for a Narrower Interpretation: The patent depicts a specific L-shaped "locking bar 62" that pivots on a "transverse pivot pin 68" and is moved by contact with a specific "engagement surface 54" on the bolt carrier (’223 Patent, col. 4:61-68; Fig. 3). An argument could be made that the term should be limited to a structure consistent with this detailed embodiment.

VI. Other Allegations

• Indirect Infringement: While the primary counts are for breach of contract and fraud, the factual allegations describe actions that constitute inducement of infringement. The complaint alleges Defendants promoted the accused products through a YouTube video, created websites for direct sales (e.g., atrius.dev), and distributed dealer pricing sheets, all of which allegedly instruct or encourage the use of infringing products (Compl. ¶63, ¶76, ¶77, ¶116).
• Willful Infringement: The complaint alleges a "knowing," "deliberate," and "brazen" scheme to violate the Settlement Agreement and Permanent Injunction (Compl. ¶4, ¶50, ¶129). The basis for knowledge is the prior litigation and the defendants' express agreement to the injunction, which establishes post-injunction knowledge of the patent and the infringing nature of the technology.

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

1. A core issue will be one of contractual scope and technical equivalence: Do the newly accused products (e.g., "Atrius Select-Fire Assisted Reset Trigger") operate in a manner that falls within the Settlement Agreement’s broad definition of a "Forced Reset Trigger," an inquiry that will likely require a technical analysis comparing their function to the claims of the ’223 Patent?
2. A second central question will be one of corporate accountability: Can the plaintiff present sufficient evidence to persuade the court that the new entities marketing the accused products (e.g., Performance Triggers Inc., Atrius Development Group Corp.) are alter egos, successors, or agents acting "in concert with" the original Settling Defendants, thereby bringing their conduct under the purview of the 2022 Permanent Injunction?
3. Finally, the case presents a question of remedy and enforcement: Given the allegations of a deliberate scheme to circumvent a federal court order through shell companies and concealed transactions, what is the appropriate scope of damages and injunctive relief required to enforce the original settlement and deter future violations?