DCT

4:25-cv-00298

Rare Breed Triggers Inc v. DNT LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00298, D. Idaho, 06/06/2025
  • Venue Allegations: Venue is alleged to be proper because Defendants reside in the district and/or have a regular and established place of business in the District of Idaho.
  • Core Dispute: Plaintiffs allege that Defendants’ “Super Safety” firearm trigger modification kits and related components contributorily infringe and induce infringement of a patent for a dual-mode, forced-reset trigger mechanism.
  • Technical Context: The technology relates to firearm trigger mechanisms designed to increase the rate of semiautomatic fire, a field with notable commercial interest and regulatory scrutiny.
  • Key Procedural History: The complaint alleges that Plaintiffs sent a cease and desist letter to Defendant Deez Nutz Tactical on March 31, 2025, providing pre-suit notice of the asserted patent and the allegedly infringing products.

Case Timeline

Date Event
2022-09-08 U.S. Patent No. 12,038,247 Priority Date
2024-07-16 U.S. Patent No. 12,038,247 Issue Date
2025-03-31 Plaintiffs' counsel sends cease and desist letter
2025-06-06 Complaint filed

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

  • Patent Identification: U.S. Patent No. 12,038,247, "Firearm Trigger Mechanism," issued July 16, 2024.

U.S. Patent No. 12,038,247 - "Firearm Trigger Mechanism"

The Invention Explained

  • Problem Addressed: The patent addresses a desire among some firearm users to increase the rate of fire in semiautomatic platforms beyond what is typically possible with a standard trigger mechanism, which requires a distinct trigger release and pull for each shot (Compl. ¶17; ’247 Patent, col. 1:30-40). The patent notes that prior methods to achieve this, such as "bump firing," are techniques rather than integrated mechanical solutions, and that "Further improvement in forced reset triggers is desired" (’247 Patent, col. 2:14-15).
  • The Patented Solution: The invention is a trigger mechanism, particularly for AR-pattern firearms, that offers two selectable modes of operation: a standard semiautomatic mode and a "forced reset" mode (Compl. ¶19). In the forced reset mode, the rearward movement of the firearm’s bolt carrier acts on a pivoting cam, which in turn mechanically forces the trigger to its reset position (’247 Patent, col. 10:49-57). In this mode, a safety selector simultaneously prevents the disconnector from catching the hammer, which allows the user to fire another round immediately upon the action returning to battery without having to manually release the trigger first (’247 Patent, Abstract).
  • Technical Importance: The invention provides a single, "drop-in" trigger module that allows a user to select between conventional semiautomatic operation and a mechanically assisted, rapid-fire capability (’247 Patent, col. 2:25-29).

Key Claims at a Glance

  • The complaint asserts at least independent claim 15 (Compl. ¶38).
  • Essential elements of independent claim 15 include:
    • A firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a movable cam with a cam lobe.
    • The mechanism has a "standard semi-automatic mode" where the cam is in a first position, and the disconnector catches the hammer after firing, requiring a manual trigger release to reset.
    • The mechanism also has a "forced reset semi-automatic mode" where the cam is in a second position.
    • In this forced reset mode, rearward movement of the bolt carrier causes the hammer to pivot, and the "disconnector hook is prevented from catching said hammer hook."
  • The complaint does not explicitly reserve the right to assert dependent claims but seeks relief for infringement of the patent generally.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as the "Super Safety" device, also referred to as the "Super Safety” (3 Position), as well as related kits ("DB9 Super Safety Curved Kit," "DB9 Super Safety Flat Kit") and individual components sold by Defendants, including precut triggers, cam levers, a "DB9 Titanium Trip Bar," and "Centering Blocks" (Compl. ¶¶21, 24-27).

Functionality and Market Context

The complaint alleges that Defendants sell kits containing a "specially made cam and cam lever that replaces a standard AR-pattern safety selector" (Compl. ¶23). When installed, the resulting assembly allegedly creates the patented invention, allowing a user to "switch between safe, standard semiautomatic with disconnector, and forced reset semiautomatic with cam modes" (Compl. ¶33). The complaint alleges these products are sold through Defendants' website and social media pages (Compl. ¶22). The complaint also accuses Defendants of selling individual components and tools, such as a "Jig" and "Go/No-Go Gauge," which are alleged to be specially designed to facilitate the creation of the infringing mechanism (Compl. ¶28). The complaint includes a photograph of the accused "Go/No-Go Gauge" tool, which appears to be designed for verifying component modifications (Compl. p. 10).

IV. Analysis of Infringement Allegations

The infringement theory is primarily one of indirect infringement, asserting that Defendants induce and contribute to infringement by selling kits and components that customers assemble into the patented mechanism (Compl. ¶¶29-32, 40-41). The complaint provides an exemplary claim chart comparing the accused device to claim 15.

'247 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
A firearm trigger mechanism comprising: The Infringing Device is for a firearm and includes a lower receiver with a fire control pocket. The provided diagram illustrates the receiver and internal pocket (Compl. p. 12). ¶39 col. 4:10-14
a hammer having a sear catch and a hook for engaging a disconnector... said hammer adapted to be pivoted rearward by rearward movement of a bolt carrier, The device is installed with a standard hammer that has a sear catch and a disconnector hook, and which is pivoted rearward by the cycling bolt carrier. ¶39 col. 7:45-48
a trigger member having a sear and adapted to be mounted in the fire control mechanism pocket to pivot... between set and released positions, The device is installed with a trigger member that has a sear and pivots between set and released positions. ¶39 col. 7:50-54
said disconnector having a hook for engaging said hammer and adapted to be mounted in the fire control mechanism pocket to pivot on a transverse disconnector pivot axis, and The device uses a disconnector with a hook for engaging the hammer, adapted to be mounted in the fire control pocket. ¶39 col. 7:61-64
a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, said cam being movable between a first position and a second position, in said second position said cam lobe forces said trigger member towards said set position, The Infringing Device has a movable cam with a cam lobe. Diagrams illustrate the cam in a first position and a second position where it forces the trigger to reset (Compl. p. 16). ¶39 col. 8:3-8
whereupon in a standard semi-automatic mode, said cam is in said first position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook... a user must manually release said trigger member... In the standard mode, the cam is in a first position, and after firing, the disconnector catches the hammer, requiring a manual trigger release. ¶39 col. 10:27-38
whereupon in a forced reset semi-automatic mode, said cam is in said second position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook... In forced reset mode, the cam is moved to a second position. A diagram shows that upon rearward movement of the bolt carrier, "the disconnector hook doesn't catch the hammer hook" (Compl. p. 18). ¶39 col. 10:39-48
  • Identified Points of Contention:
    • Scope Questions: Claim 15 requires that in forced reset mode, the "disconnector hook is prevented from catching said hammer hook." The patent specification describes this being achieved by a portion of the safety selector physically blocking the disconnector from pivoting (’247 Patent, col. 8:58-64). A central question for the court will be whether the term "prevented" is limited to the specific blocking mechanism shown in the patent's figures and description, or if it can read on any mechanism that achieves the same result.
    • Technical Questions: The complaint's infringement theory relies on indirect infringement. A key factual question will be whether the components sold by Defendants—such as the "Super Safety" cam levers, "DB9 Titanium Trip Bar," and "Centering Blocks" (Compl. ¶¶24, 26, 27)—are staple articles of commerce with substantial non-infringing uses, or if they are, as alleged, material parts of the invention especially made or adapted for an infringing purpose.

V. Key Claim Terms for Construction

  • The Term: "prevented from catching"
  • Context and Importance: This phrase is central to defining the novel "forced reset" mode that distinguishes the invention from a standard semiautomatic trigger. The mechanism by which the disconnector is "prevented" from working is the key to enabling a faster rate of fire. Practitioners may focus on this term because its construction will determine whether infringement requires the specific physical blocking action shown in the patent's embodiments or covers other methods of disabling the disconnector.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is functional, describing the result (the hook is "prevented from catching") rather than the structure that causes it. A plaintiff could argue this functional language is not limited to any specific embodiment.
    • Evidence for a Narrower Interpretation: The detailed description explains that a "narrow semi-circular portion 116" of the safety selector "prevents the disconnector 60 from pivoting," thus disabling it (’247 Patent, col. 8:58-64). A defendant could argue that the claims should be interpreted in light of this specific, and only, disclosed mechanism for achieving the "prevention."

VI. Other Allegations

  • Indirect Infringement: The complaint is founded on allegations of indirect infringement.
    • Induced Infringement (35 U.S.C. § 271(b)): The complaint alleges Defendants instruct customers on how to assemble the infringing devices, citing an instruction link on Defendants' website (Compl. ¶¶25, 32). This is alleged as evidence of Defendants' specific intent to cause infringement.
    • Contributory Infringement (35 U.S.C. § 271(c)): The complaint alleges that Defendants sell key components (e.g., the cam lever, trip bar, centering blocks) that are material parts of the patented invention, are specially designed for use in an infringing manner, and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶26-28, 40).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants’ continued sale of the accused products after receiving a cease and desist letter dated March 31, 2025, which allegedly provided actual notice of the patent and infringement (Compl. ¶¶14, 36).

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

  1. A central issue will be one of indirect liability: As the Defendants are accused of selling kits and components rather than fully assembled mechanisms, the case will depend on whether Plaintiffs can prove the statutory requirements for contributory and induced infringement. This will involve factual questions about the nature of the sold components (i.e., whether they are staple articles of commerce) and the Defendants' intent, for which Plaintiffs point to alleged assembly instructions (Compl. ¶25, ¶32).

  2. A key legal question will be one of claim scope: The construction of the functional limitation "disconnector hook is prevented from catching said hammer hook" will be critical. The outcome of the case may turn on whether the court determines this language covers any means of disabling the disconnector or limits the claim to the specific physical blocking mechanism detailed in the patent’s specification.