ABC IP LLC v. Cloak Industries Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and RARE BREED TRIGGERS, INC. (Texas)
  • Defendant: Cloak Industries, Inc. (Idaho) and William C. King Jr. (Idaho)
  • Plaintiff’s Counsel: Beard St. Clair Gaffney PA; Wood Herron & Evans LLP
• Case Identification: 1:26-cv-00001, D. Idaho, 01/05/2026
• Venue Allegations: Venue is alleged to be proper in the District of Idaho because the Defendants reside in and/or maintain a regular and established place of business within the district.
• Core Dispute: Plaintiffs allege that Defendants’ "Partisan Disruptor" trigger assembly infringes four patents related to "forced reset" firearm trigger mechanisms.
• Technical Context: The technology concerns aftermarket trigger mechanisms for AR-15 pattern firearms designed to increase the achievable rate of semiautomatic fire by using the firearm's cycling action to mechanically reset the trigger.
• Key Procedural History: The complaint alleges that the manufacturer of the accused device maintains a website with a "Legal Library" linking to copies of the patents-in-suit, which Plaintiffs assert serves as a basis for Defendants' knowledge of the patents and willful infringement.

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
2022-01-10	U.S. Patent No. 11,724,003 Priority Date
2022-01-10	U.S. Patent No. 12,036,336 Priority Date
2022-01-10	U.S. Patent No. 12,274,807 Priority Date
2023-08-15	U.S. Patent No. 11,724,003 Issued
2024-07-16	U.S. Patent No. 12,036,336 Issued
2025-04-15	U.S. Patent No. 12,274,807 Issued
2026-01-05	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 background describes a desire among firearm users to increase the rate of semiautomatic fire beyond what is typically possible with a standard trigger mechanism, which requires the user to manually release and reset the trigger between shots (’223 Patent, col. 1:37-41). Existing methods to achieve this, such as "bump firing," are described as processes requiring practice or involving complex or expensive devices (’223 Patent, col. 1:41-col. 2:16).
• The Patented Solution: The invention provides a "drop-in" trigger module that uses the firearm's natural action cycle to mechanically reset the trigger without user intervention (’223 Patent, col. 2:30-38). As the bolt carrier moves rearward after firing, it pushes the hammer back into a cocked position. This rearward pivoting of the hammer makes contact with a surface on the trigger member, forcing the trigger itself back to its forward, reset position (’223 Patent, col. 5:30-40). A separate "locking bar" then blocks the trigger from being pulled again until the bolt carrier has returned to its "in-battery" (fully forward and locked) position, which prevents malfunctions such as "hammer follow" (’223 Patent, col. 5:40-49).
• Technical Importance: This approach provides a self-contained mechanical solution to increase the potential rate of fire that can be retrofitted into standard AR-pattern firearms without modifying other key components like the bolt carrier (’223 Patent, col. 2:30-38).

Key Claims at a Glance

• The complaint asserts independent Claim 4.
• Essential elements of Claim 4 include:
  • A housing with openings for hammer and trigger assembly pins.
  • A hammer with a sear notch, mounted to pivot between set and released positions.
  • A trigger member with a sear and a surface positioned to be contacted by the hammer when the bolt carrier cycles, with this contact 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, but is moved out of the way when contacted by the bolt carrier as it reaches a "substantially in-battery position."
• The complaint does not explicitly reserve the right to assert dependent claims.

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

The Invention Explained

• Problem Addressed: The patent background describes the same general problem as the '223 Patent—the desire to increase the rate of fire in semiautomatic firearms—but implies a need for more user control than a dedicated forced-reset trigger provides (’003 Patent, col. 1:38-42).
• The Patented Solution: This patent builds upon the forced-reset concept by introducing a user-selectable, multi-mode functionality via a three-position safety selector (’003 Patent, Abstract). The user can choose between: (1) a safe position, (2) a "standard semi-automatic" mode where a traditional disconnector catches the hammer and requires a manual trigger release to reset, and (3) a "forced reset semi-automatic" mode where the cycling of the bolt carrier forces the trigger to reset, similar to the '223 Patent's mechanism (’003 Patent, col. 2:33-42). This dual-functionality is achieved through the interaction of the safety selector with the disconnector.
• Technical Importance: This invention provides the functionality of a forced-reset trigger while also allowing the user to revert to the familiar operation of a standard semiautomatic trigger within the same self-contained module (’003 Patent, col. 2:33-37).

Key Claims at a Glance

• The complaint asserts independent Claim 4.
• Essential elements of Claim 4 include:
  • A housing, hammer, trigger member, locking member, and a disconnector.
  • A safety selector adapted to pivot between "safe, standard semiautomatic, and forced reset semiautomatic positions."
  • A "whereupon" clause defining operation in the standard mode, where the disconnector hook catches the hammer hook, requiring a manual trigger release.
  • A "whereupon" clause defining operation in the forced reset mode, where the bolt carrier's movement forces the trigger to its set position, the safety selector prevents the disconnector from catching the hammer, and the user can fire again once the bolt is in battery without manually releasing the trigger.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

• Technology Synopsis: The patent describes a trigger mechanism for AR-pattern firearms featuring a three-position safety selector that allows the user to switch between safe, standard semiautomatic, and forced reset semiautomatic modes (’336 Patent, Abstract). A key aspect of the invention is the specific claim that in the forced reset mode, the safety selector "causes said disconnector to be repositioned and in doing so prevents said disconnector hook from catching said hammer hook" (’336 Patent, col. 12:39-44).
• Asserted Claims: The complaint asserts independent Claim 3 (Compl. ¶50).
• Accused Features: The complaint alleges that the "Partisan Disruptor" trigger includes a three-position safety selector that embodies the claimed multi-mode functionality, including the specific interaction between the selector and the disconnector to enable the forced reset mode (Compl. ¶51, p. 20).

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

• Technology Synopsis: The technology is a trigger mechanism for an AR-pattern firearm that incorporates a hammer, trigger, disconnector, locking member, and a three-position safety selector (’807 Patent, Abstract). The invention provides selectable safe, standard semiautomatic, and forced reset semiautomatic operational modes, with detailed functional limitations describing the mechanical interactions in each mode.
• Asserted Claims: The complaint asserts independent Claim 1 (Compl. ¶57).
• Accused Features: The complaint alleges that the "Partisan Disruptor" trigger assembly, with its three-position selector and its operation in both standard and forced reset modes, infringes the combination of elements claimed in the '807 Patent (Compl. ¶58, pp. 22-25).

III. The Accused Instrumentality

Product Identification

• The accused product is the "Partisan Disruptor," which the complaint describes as a "forced reset trigger assembly, which includes a three-position safety selector" (Compl. ¶23).

Functionality and Market Context

• The complaint alleges the Partisan Disruptor is a "3 Position Drop-In Forced Reset Trigger" marketed for AR-pattern firearms (Compl. ¶¶ 12, 17, 22). The complaint provides an image from the Defendants' website showing the assembled trigger mechanism and associated components (Compl. ¶24, p. 5).
• Functionally, the device is alleged to operate in multiple modes selected by the user. In "forced reset mode," the cycling of the firearm's action causes hammer contact with the trigger member to reset it, while a locking bar prevents premature firing (Compl. ¶26). In "disconnector mode" or "standard semiautomatic mode," the device operates like a standard AR-15 trigger, where the user must manually release the trigger to reset the disconnector (Compl. ¶¶ 25, 28). The complaint includes an annotated photograph of the accused device's safety selector, which enables switching between these modes (Compl. ¶51, p. 20). The complaint alleges the product is offered for sale on the Defendants' website (Compl. ¶24).

IV. Analysis of Infringement Allegations

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

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins;	The device includes a housing with transversely aligned openings for receiving hammer and trigger assembly pins.	¶37, p. 9	col. 3:35-49
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The device includes a hammer with a sear notch mounted in the housing to pivot between set and released positions.	¶37, p. 10	col. 3:12-28
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 device includes a trigger member with a sear that pivots in the housing. It has a surface contacted by the hammer during cycling, which forces the trigger member to the set position. The complaint provides an annotated visual identifying the "Trigger surface" and "Hammer surface" that allegedly interact (Compl. ¶37, p. 11).	¶37, pp. 10-11	col. 4:1-8
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, and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position...	The device includes a pivotally mounted, spring-biased locking bar that blocks the trigger member from moving. It is moved to a second position by contact with the bolt carrier when it reaches the in-battery position, allowing the trigger to be pulled.	¶37, p. 11	col. 4:61-67

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

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a firearm trigger mechanism comprising: a housing...a hammer...a trigger member...a disconnector...a locking member...	The Infringing Device is a firearm trigger mechanism comprising these structural elements.	¶44, pp. 12-15	col. 7:45-col. 8:50
a safety selector adapted to be mounted...to pivot between safe, standard semiautomatic, and forced reset semiautomatic positions,	The device includes a safety selector that pivots between safe, standard semiautomatic, and forced reset semiautomatic positions.	¶44, p. 15	col. 9:11-20
whereupon in said standard semiautomatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook, at which time a user must manually release said trigger member...	When in standard mode, the bolt carrier's rearward movement causes the hammer to pivot, allowing the disconnector hook to catch the hammer hook, requiring a manual trigger release to fire again. The complaint includes a visual identifying the alleged "Disconnector hook" and "Hammer hook" (Compl. ¶44, p. 16).	¶44, p. 16	col. 9:35-53
whereupon in said forced reset semiautomatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer causing said trigger member to be forced to said set position, said safety selector preventing said disconnector hook from catching said hammer hook, and thereafter when the bolt carrier reaches the substantially in-battery position the user can pull said trigger member to fire the firearm without manually releasing said trigger member.	When in forced reset mode, the bolt carrier's movement forces the trigger to reset, the safety selector prevents the disconnector from engaging the hammer, and the user can fire again once the bolt is in battery without a manual trigger release.	¶44, p. 16	col. 10:1-26

Identified Points of Contention

• Scope Questions: The infringement analysis for the '223 Patent may raise the question of whether a device capable of operating in multiple modes can infringe a patent that claims only one of those modes. Plaintiffs allege that the "presence of another mode of operation... does not affect the infringement analysis as to the '223 Patent claims" (Compl. ¶26), a position a defendant would likely contest.
• Technical Questions: For the '003, '336, and '807 patents, the dispute may center on the precise mechanical operation described in the functional "whereupon" clauses. A key question for the court will be whether the accused Partisan Disruptor's safety selector "prevents" the disconnector from catching the hammer hook through the same mechanical means and sequence as required by the claims, or if it achieves a similar result through a different, non-infringing interaction.

V. Key Claim Terms for Construction

• The Term: "contact causing the trigger member to be forced to the set position" ('223 Patent, Claim 4; '003 Patent, Claim 4)

  • Context and Importance: This phrase is the core of the "forced reset" invention. Its construction will determine the required nature of the interaction between the hammer and the trigger. Practitioners may focus on this term because the specific geometry, timing, and force of this contact are central to the mechanism's operation and distinguish it from standard designs where no such interaction occurs.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, requiring only "contact" that "causes" the trigger to be "forced." This could be read to cover any interaction, direct or indirect, that results in the trigger resetting.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where "mechanical interference or contact between a rear surface 74 of the hammer 18... and a contact surface 30 of the trigger member 26 forces the trigger to pivot... toward and to its reset position" (’223 Patent, col. 5:34-39). A defendant may argue this language limits the term to the specific, direct surface-to-surface contact shown in the patent's figures.

• The Term: "substantially in-battery position" ('223 Patent, Claim 4; '003 Patent, Claim 4)

  • Context and Importance: This term defines the safety window for when the locking bar disengages and allows the trigger to be pulled again. Its definition is critical for both infringement and safety, as firing a weapon that is not fully "in-battery" can be dangerous. Practitioners may focus on this term because "substantially" is a term of degree whose scope is not explicitly defined.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the purpose is to prevent "early hammer release or 'hammer follow' against the bolt carrier assembly" (’223 Patent, col. 5:47-49). This suggests "substantially" could mean any position close enough to being fully in-battery to prevent this specific malfunction.
    • Evidence for a Narrower Interpretation: The specification notes that this interaction "prevents early release of the hammer... before the bolt is completely locked and in-battery" (’223 Patent, col. 5:65-67). This language may support an argument that "substantially" requires the bolt to be very close to, if not fully, locked for safety reasons.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant William C. King Jr. "directed Cloak to infringe the Plaintiffs' patent rights" (Compl. ¶32). However, the enumerated counts are for direct infringement under 35 U.S.C. § 271(a) (Compl. ¶¶ 35, 43, 50, 57). The complaint does not provide sufficient detail for analysis of indirect infringement beyond this single allegation.
• Willful Infringement: Willfulness is alleged based on Defendants' purported pre-suit knowledge of the patents-in-suit (Compl. ¶33). The complaint alleges this knowledge stems from a "Legal Library" webpage on the website of the accused device's manufacturer, which allegedly links to copies of Plaintiffs' patents (Compl. ¶¶ 30-31).

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

• A central issue will be one of mechanical operation and timing: Does the accused "Partisan Disruptor" execute the precise sequence of mechanical events described in the functional "whereupon" clauses of the asserted claims? Specifically, does its safety selector "prevent" the disconnector from engaging the hammer, and does its locking bar disengage at a moment corresponding to the claimed "substantially in-battery position"?
• A key legal question will be one of infringement by capability: For the '223 Patent, which does not claim mode selection, can infringement be found based on the accused device’s ability to operate in a "forced reset" mode, even if it is also capable of operating in a different, "standard" mode not covered by that patent's claims?
• A significant evidentiary question regarding willfulness will be one of imputed knowledge: Can knowledge of the patents-in-suit be imputed to the defendant reseller (Cloak Industries) and its principal based on the public availability of those patents on a third-party manufacturer's website, and does this rise to the level of egregious conduct required for a finding of willfulness?