DCT

4:25-cv-00299

ABC IP LLC v. Harrison Gunworks LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00299, D. Idaho, 06/06/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Idaho on the basis that Defendants reside in and/or have a regular and established place of business in the district.
  • Core Dispute: Plaintiffs allege that Defendants’ "Super Safety" and "Defender FRT" firearm trigger mechanisms infringe five patents related to forced reset triggers that can operate in multiple modes.
  • Technical Context: The technology concerns trigger mechanisms for AR-15-pattern semiautomatic firearms, specifically "forced reset triggers" (FRTs), which use the firearm's cycling action to reset the trigger, potentially enabling a higher rate of fire than standard mechanisms.
  • Key Procedural History: Plaintiffs allege they sent a cease-and-desist letter to Defendant Gunworks on March 28, 2025, regarding the ’247 Patent. A subsequent message was allegedly sent on May 8, 2024, regarding the ’223, ’003, ’336, and ’807 Patents in view of a newly offered product. These communications are cited as the basis for willful infringement.

Case Timeline

Date Event
2017-09-29 ’223 Patent Priority Date
2019-12-24 ’223 Patent Issue Date
2022-01-10 ’003, ’336, ’807 Patents Priority Date
2022-09-08 ’247 Patent Priority Date
2023-08-15 ’003 Patent Issue Date
2024-05-08 Plaintiffs' counsel allegedly sent message to Defendants' counsel regarding ’223, ’003, ’336, and ’807 Patents
2024-07-16 ’247 and ’336 Patents Issue Date
2025-03-28 Plaintiffs' counsel allegedly sent cease-and-desist letter regarding ’247 Patent
2025-04-15 ’807 Patent Issue Date
2025-06-06 Complaint Filing Date

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

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

The Invention Explained

  • Problem Addressed: The patent background describes a desire among shooters to increase the rate of semiautomatic fire, noting that users have employed techniques like "bump firing" which can be inconsistent. (Compl., Ex. A, ’247 Patent, col. 1:18-56).
  • The Patented Solution: The invention is a trigger mechanism for AR-pattern firearms that provides multiple modes of operation, including a standard semiautomatic mode and a "forced reset" mode. (’247 Patent, Abstract). In the forced reset mode, a pivoting cam, actuated by the rearward movement of the bolt carrier, forces the trigger member back to its set position, allowing a user to fire again without manually releasing the trigger. (’247 Patent, Abstract; col. 2:50-67). This mechanism is designed to be a "drop-in" assembly that does not require modification of other standard firearm components. (’247 Patent, col. 2:20-29).
  • Technical Importance: The technology provides a mechanical means to increase the potential rate of fire in a standard semiautomatic firearm platform without altering the fundamental one-shot-per-trigger-pull operation. (Compl., Ex. A, ’247 Patent, col. 1:18-21).

Key Claims at a Glance

  • The complaint asserts independent claim 15. (Compl. ¶45).
  • Claim 15 recites a firearm trigger mechanism comprising:
    • a hammer with a sear catch and hook, pivotable between set and released positions.
    • a trigger member with a sear, also pivotable between set and released positions.
    • a disconnector with a hook for engaging the hammer.
    • a cam with a cam lobe, movable between a first and second position, where in the second position the cam lobe forces the trigger member towards its set position.
    • operation in a "standard semi-automatic mode" where the cam is in the first position and the disconnector catches the hammer.
    • operation in a "forced reset semi-automatic mode" where the cam is in the second position and prevents the disconnector from catching the hammer, allowing the user to fire again upon the bolt carrier returning to battery.

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

The Invention Explained

  • Problem Addressed: Similar to the ’247 Patent, the background describes the desire to increase the rate of semiautomatic fire and notes that prior art solutions were either complex, expensive, or required modification of the host firearm. (Compl., Ex. B, ’223 Patent, col. 2:1-17).
  • The Patented Solution: The patent describes a trigger mechanism where the cycling of the bolt carrier causes the hammer to make contact with the trigger member, forcing the trigger to its reset position. (’223 Patent, Abstract). A key component is a "locking bar" that is pivotally mounted and spring-biased to block the trigger from moving to the released position until the bolt carrier has returned to its "substantially in-battery position," at which point the bolt carrier contacts the locking bar and moves it, allowing the trigger to be pulled. (’223 Patent, Abstract; col. 6:38-45).
  • Technical Importance: This design aims to provide a reliable forced-reset functionality while including a safety feature (the locking bar) to prevent "hammer follow," where the hammer follows the bolt carrier forward without firing, leaving the firearm uncocked. (Compl., Ex. B, ’223 Patent, col. 2:44-47).

Key Claims at a Glance

  • The complaint asserts independent claim 4. (Compl. ¶54).
  • Claim 4 recites a trigger mechanism for a firearm, comprising:
    • a housing with aligned openings for hammer and trigger assembly pins.
    • a hammer with a sear notch, mounted in the housing.
    • a trigger member with a sear, mounted in the housing, having a surface to be contacted by the hammer when displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position.
    • a locking bar pivotally mounted in the housing, spring-biased to a first position where it blocks the trigger, and movable to a second position by the bolt carrier reaching an in-battery position, where it no longer blocks the trigger.

U.S. Patent No. 11,724,003 - "Firearm Trigger Mechanism," issued August 15, 2023.

  • Technology Synopsis: The complaint alleges this patent, along with the ’336 and ’807 patents, describes and claims a device similar to that of the ’223 Patent, with the additional feature that it can be selected to operate in either a standard semiautomatic mode (with a disconnector) or a forced reset mode. (Compl. ¶25). This selection is accomplished via a "three position" safety selector. (Compl., Ex. C, ’003 Patent, Abstract).
  • Asserted Claims: Independent Claim 4 is asserted. (Compl. ¶62).
  • Accused Features: The "Defender FRT" drop-in trigger mechanism is accused of infringing this patent. (Compl. ¶¶ 38, 41, 62).

U.S. Patent No. 12,036,336 - "Firearm Trigger Mechanism," issued July 16, 2024.

  • Technology Synopsis: The complaint alleges this patent is part of a family with the ’003 and ’807 patents, describing a selectable, dual-mode (standard semi-auto and forced reset) trigger mechanism featuring a locking member and a three-position safety selector. (Compl. ¶25). The selector, when in the forced reset position, repositions the disconnector to prevent it from engaging the hammer. (Compl., Ex. D, ’336 Patent, Abstract).
  • Asserted Claims: Independent Claim 3 is asserted. (Compl. ¶69).
  • Accused Features: The "Defender FRT" drop-in trigger mechanism is accused of infringing this patent. (Compl. ¶¶ 38, 41, 69).

U.S. Patent No. 12,274,807 - "Firearm Trigger Mechanism," issued April 15, 2025.

  • Technology Synopsis: The complaint alleges this patent is part of a family with the ’003 and ’336 patents, describing a selectable, dual-mode (standard semi-auto and forced reset) trigger mechanism featuring a locking member and a three-position safety selector. (Compl. ¶25). The technology is designed as a "drop-in" module for AR-pattern firearms. (Compl., Ex. E, ’807 Patent, Abstract).
  • Asserted Claims: Independent Claim 1 is asserted. (Compl. ¶76).
  • Accused Features: The "Defender FRT" drop-in trigger mechanism is accused of infringing this patent. (Compl. ¶¶ 38, 41, 76).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two accused product lines: the "Super Safety" (3 Position) kit (the "Infringing Device") and the "Defender FRT" drop-in trigger mechanism (the "Infringing Unit"). (Compl. ¶¶ 28, 38).

Functionality and Market Context

  • The "Super Safety" is described as a kit containing a specially made cam and cam lever that replaces a standard AR-pattern safety selector, along with a specially cut trigger member. (Compl. ¶30). When installed with a standard hammer and disconnector, it allegedly creates the invention of the ’247 Patent, providing selectable modes for safe, standard semiautomatic, and forced reset operation. (Compl. ¶¶ 30, 35).
  • The "Defender FRT" is described as a complete, drop-in trigger mechanism replacement. (Compl. ¶38). This product is alleged to operate as a dual-mode device, with a standard disconnector mode and a forced reset mode, embodying the technology of the ’223, ’003, ’336, and ’807 Patents. (Compl. ¶¶ 39-41). The complaint includes a screenshot of an online advertisement for the "Defender FRT" which describes its "3 position cassette-style" and "seamless transitions between Safe, Traditional Semi, and Forced Reset Semi." (Compl. ¶39, p. 9).

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,038,247 Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
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 includes a cam with a cam lobe that is movable between a first and second position. The complaint provides a diagram alleging that in the second position, the lobe forces the trigger member toward its set position. (Compl. p. 14). ¶46 col. 8:1-12
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... In standard semi-automatic mode, the cam is allegedly moved to a first position, allowing the disconnector to catch the hammer after the bolt carrier cycles. ¶46 col. 9:56-68
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 allegedly moved to a second position, which prevents the disconnector from catching the hammer hook, allowing the user to fire again after the bolt carrier returns to battery. ¶46 col. 10:1-14
  • Identified Points of Contention:
    • Scope Questions: The case may turn on whether the accused "cam and cam lever that replaces a standard AR-pattern safety selector" (Compl. ¶30) falls within the scope of the claimed "cam." A dispute could arise over whether a component that also functions as a safety selector meets the definition of "cam" as used in the patent.
    • Technical Questions: A key factual question may be the precise mechanical interaction in the accused device. Specifically, what evidence demonstrates that the accused cam, in its second position, "prevents" the disconnector from catching the hammer hook, as required by the claim, versus merely disabling it or moving it out of the way through a different mechanism?

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

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
a trigger member having a sear... 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 Infringing Unit allegedly includes a trigger with a surface that is contacted by the hammer during cycling, which forces the trigger to the set position. The complaint includes a photograph indicating the "Hammer surface" and "Trigger surface" that allegedly perform this function. (Compl. p. 20). ¶56 col. 5:29-37
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 Infringing Unit includes a pivotally mounted locking bar, which is allegedly spring-biased to a first position to block the trigger. ¶56 col. 6:38-45
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 movable to a second position when contacted by the bolt carrier as it returns to battery, which unblocks the trigger and allows the firearm to be fired. A photograph in the complaint labels the accused "Locking member." (Compl. p. 21). ¶56 col. 5:3-13
  • Identified Points of Contention:
    • Scope Questions: The construction of "substantially in-battery position" could be a point of dispute. The parties may contest the precise point in the bolt carrier's forward travel at which the locking bar is moved enough to permit firing and whether the accused device meets this temporal and mechanical requirement.
    • Technical Questions: The complaint alleges the "contact causes the trigger member to be forced to the set position." (Compl. ¶56). A central factual question will be whether the interaction in the accused "Defender FRT" is a direct forcing of the trigger by the hammer, as claimed, or if another component or interaction achieves the reset.

V. Key Claim Terms for Construction

Term from ’247 Patent: "cam"

  • The Term: "cam"
  • Context and Importance: The identity and function of the "cam" is the central element of the asserted claim distinguishing between the two operational modes. Whether the accused "Super Safety" selector qualifies as a "cam" will be a dispositive issue. Practitioners may focus on this term because the accused component is also a safety selector, and its dual function could be argued to distinguish it from the claimed element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the cam's function broadly as being "pivotable between a first position...and a second position" and having a lobe that "forces the trigger member." (’247 Patent, col. 10:48-55). This functional language may support a construction that covers any component achieving this result, regardless of its other functions.
    • Evidence for a Narrower Interpretation: The figures consistently depict the cam (72) as a distinct component that is acted upon by the safety selector (110) but is not the selector itself. (e.g., ’247 Patent, Fig. 8A). The detailed description states "the cam 72 can be pivoted on a cam pin 74," which is separate from the pivot of the safety selector. (’247 Patent, col. 8:1-3). This may support a narrower construction requiring a separate component.

Term from ’223 Patent: "locking bar"

  • The Term: "locking bar"
  • Context and Importance: The "locking bar" provides the critical safety function of preventing out-of-battery firing. The infringement analysis will depend on whether the accused component in the "Defender FRT" performs the specific blocking and unblocking functions as described in the claim. The timing of its interaction with the bolt carrier is central to the invention's operation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim describes the locking bar functionally as being "movable against the spring bias...when contacted by the bolt carrier." (’223 Patent, col. 8:8-10). This could be interpreted to cover any component that is moved by the bolt carrier at the appropriate time to unblock the trigger.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the locking bar is "pivotally mounted in a frame" and the bolt carrier contacts it to allow movement. (’223 Patent, Abstract). The figures show a distinct, pivoted component (62). (e.g., ’223 Patent, Fig. 2). This may support a construction limited to a pivoted bar, as opposed to a sliding or otherwise actuated blocking mechanism.

VI. Other Allegations

  • Indirect Infringement: For the ’247 Patent, the complaint alleges both contributory and induced infringement. Contributory infringement is based on allegations that Defendants sell components—the cam, lever, and trigger—that are "especially made or especially adapted for use in an infringement" and are not staple articles of commerce. (Compl. ¶¶ 31-32, 47). Inducement is based on allegations that "Defendant instructed purchasers to assemble the Infringing Devices in a way that induces infringement." (Compl. ¶¶ 34, 48).
  • Willful Infringement: The complaint alleges willful infringement of all five patents. (Compl. ¶¶ 18, 43, 51, 59, 66, 73, 80). The basis for willfulness is alleged pre-suit knowledge based on a cease-and-desist letter sent March 28, 2025, regarding the ’247 Patent and a subsequent communication on May 8, 2024, regarding the remaining four patents. (Compl. ¶¶ 19-20).

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

  • A core issue will be one of structural and definitional scope: Does the accused "Super Safety" product, which integrates its cam function into a replacement safety selector, constitute the claimed "cam" of the ’247 Patent, which the patent figures depict as a distinct component?
  • A second central question will be one of functional mechanics: For the family of patents including the ’223 Patent, does the accused "Defender FRT" utilize a "locking bar" that operates in the specific manner claimed—being moved from a blocking to a non-blocking position by direct contact from the bolt carrier as it reaches a "substantially in-battery position"?
  • An underlying evidentiary question will be one of intent: Can Plaintiffs produce sufficient evidence that Defendants, after receiving pre-suit notice via the alleged communications, acted with the knowledge and intent required to support the claims for indirect and willful infringement?