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
• 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 and/or maintain a regular and established place of business within the district.
• Core Dispute: Plaintiffs allege that Defendants’ "Partisan Disruptor" firearm trigger infringes four patents related to "forced reset" trigger mechanisms that use the cycling of a firearm's action to mechanically reset the trigger.
• Technical Context: The technology concerns aftermarket trigger assemblies for semi-automatic firearms, primarily AR-15 pattern rifles, designed to increase the potential rate of fire beyond that achievable with a standard trigger mechanism.
• Key Procedural History: The complaint alleges that the manufacturer of the accused device maintains a website with a "Legal Library" that includes links to copies of several of the asserted patents, which Plaintiffs present as evidence of Defendants' knowledge and willful infringement.

Case Timeline

Date	Event
2017-09-29	Earliest Priority Date for ’223 Patent
2019-12-24	’223 Patent Issued
2022-01-10	Earliest Priority Date for ’003, ’336, and ’807 Patents
2023-08-15	’003 Patent Issued
2024-07-16	’336 Patent Issued
2025-04-15	’807 Patent Issued
2026-01-05	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: In a standard semi-automatic firearm, the rate of fire is limited by the need for a user to manually release the trigger to allow a disconnector to reset the hammer and sear mechanism for the next shot (’223 Patent, col. 1:24-32). Existing methods to increase this rate, such as "bump firing," are described as having drawbacks (’223 Patent, col. 1:41-51).
• The Patented Solution: The patent describes a trigger mechanism where the hammer, as it is pushed rearward by the cycling bolt carrier, makes direct contact with the trigger member, mechanically forcing the trigger to its reset position (’223 Patent, Abstract; col. 5:32-38). A separate, pivotally mounted "locking bar" then blocks the trigger from being pulled again until the bolt carrier has returned to a "substantially in-battery position," at which point the bolt carrier contacts and moves the locking bar, unblocking the trigger and allowing the firearm to be fired again (’223 Patent, col. 5:56-6:2). This design obviates the need for a traditional disconnector to prevent hammer follow (’223 Patent, Abstract).
• Technical Importance: This approach is presented as a "drop-in" replacement module for popular firearm platforms like the AR-15, enabling an increased rate of fire without requiring modification of other key components like the bolt carrier (’223 Patent, col. 2:30-38).

Key Claims at a Glance

• The complaint asserts independent claim 4 (Compl. ¶35).
• The essential elements of Claim 4 include:
  • 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 and a surface positioned to be contacted by the hammer when the bolt carrier cycles, with this contact "causing the trigger member to be forced to the set position."
  • A pivotally mounted locking bar, spring-biased to a first position where it "mechanically blocks the trigger member," and movable to a second position when contacted by the bolt carrier upon reaching a "substantially in-battery position," allowing the trigger to be moved by an external force (’223 Patent, col. 6:57-7:14).

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

Issued August 15, 2023

The Invention Explained

• Problem Addressed: Building on the concept of a forced reset trigger, this patent addresses the desire to provide this functionality as a user-selectable option alongside standard semi-automatic operation (Compl. ¶21; ’003 Patent, col. 1:11-14).
• The Patented Solution: The invention adds a three-position safety selector that allows the user to switch between "safe," "standard semi-automatic," and "forced reset semi-automatic" modes (’003 Patent, Abstract). In the standard mode, a traditional disconnector engages the hammer hook, requiring the user to manually release the trigger to reset it (’003 Patent, col. 2:3-8). In the forced reset mode, the safety selector physically prevents the disconnector from catching the hammer hook, thereby enabling the hammer-contact reset mechanism to function as the primary means of resetting the trigger (’003 Patent, col. 2:8-13).
• Technical Importance: The invention integrates both a traditional disconnector-based firing mode and a rapid-fire forced-reset mode into a single trigger assembly, offering greater versatility to the user (’003 Patent, col. 1:28-34).

Key Claims at a Glance

• The complaint asserts independent claim 4 (Compl. ¶43).
• The essential elements of Claim 4 include:
  • A housing, a hammer with a sear catch and hook, a trigger member with a sear and a contact surface, a disconnector with a hook, and a locking member.
  • A "safety selector" adapted to pivot between "safe, standard semiautomatic, and forced reset semiautomatic positions."
  • An operational definition for the standard mode, where the disconnector hook catches the hammer hook, requiring a manual trigger release.
  • An operational definition for the forced reset mode, where the cycling bolt carrier forces the trigger to reset, and the safety selector "preventing said disconnector hook from catching said hammer hook" (’003 Patent, col. 11:37-12:50).

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

Issued July 16, 2024

• Technology Synopsis: The patent describes a selectable firearm trigger mechanism that incorporates a hammer, trigger member, disconnector, locking member, and a safety selector. In the "forced reset" position, the safety selector is configured to cause the disconnector to be repositioned, which in turn "prevents said disconnector hook from catching said hammer hook," enabling the forced reset function (’336 Patent, col. 15:1-12). In the standard semi-automatic mode, the disconnector functions traditionally.
• Asserted Claims: Independent Claim 3 (Compl. ¶50).
• Accused Features: The complaint alleges the "Partisan Disruptor" infringes by incorporating a three-position safety selector that, in the forced reset mode, prevents the disconnector from engaging the hammer, thereby enabling the forced reset functionality (Compl. ¶¶ 25, 27, 51).

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

Issued April 15, 2025

• Technology Synopsis: The patent details a trigger mechanism with selectable modes of operation for AR-pattern firearms. The invention includes a hammer, trigger, disconnector, locking member, and a "movably mounted" safety selector. The claims describe the sequence of operations in both standard mode (disconnector catches hammer hook) and forced reset mode (bolt carrier resets trigger, safety selector prevents disconnector engagement) (’807 Patent, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶57).
• Accused Features: The complaint accuses the "Partisan Disruptor" of infringing by having a movably mounted safety selector that allows the user to switch between a standard mode where the disconnector operates and a forced reset mode where it is prevented from operating, in combination with the other claimed elements (Compl. ¶¶ 25, 27, 58).

III. The Accused Instrumentality

Product Identification

The "Partisan Disruptor," described 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 drop-in trigger mechanism for AR-15 pattern firearms sold via the website cloak-industries.com (Compl. ¶¶ 24, 37). It is alleged to operate in three modes selectable by the user: safe, standard semi-automatic, and forced reset semi-automatic (Compl. ¶25). In the forced reset mode, the cycling of the firearm's action is alleged to cause "hammer contact with the trigger member to forcefully reset the hammer and trigger member," while a "locking bar/member" prevents the trigger from being pulled again until the bolt carrier has returned to the in-battery position (Compl. ¶26). In the standard semi-automatic mode, it is alleged to operate like a standard AR-15 trigger using a disconnector (Compl. ¶25, 28). The complaint provides product photographs of the accused trigger assembly. One photograph shows the assembled trigger mechanism and its component parts. (Compl. p. 5).

IV. Analysis of Infringement Allegations

’223 Patent 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 pairs of openings for receiving hammer and trigger assembly pins.	¶37	col. 6:58-60
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 on a transverse axis.	¶37	col. 6:61-63
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions, 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 and a surface positioned to be contacted by the hammer during cycling, which forces the trigger member to the set position. An image in the complaint's claim chart labels the specific "Trigger surface" and "Hammer surface" that allegedly interact to force the reset. (Compl. p. 11).	¶37	col. 6:64-7:3
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 in which the trigger member can be moved by an external force to the released position.	The device includes a pivotally mounted, spring-biased locking bar that blocks the trigger member and is moved to an unblocked position by contact from the bolt carrier when it reaches an in-battery position. The complaint provides an annotated photograph identifying the "Locking bar" and its "Pivot." (Compl. p. 11).	¶37	col. 7:4-14

Identified Points of Contention

• Technical Questions: A central factual question may be whether the contact between the accused device's hammer and trigger is the sole or primary cause that "force[s]" the trigger to the set position, as required by the claim, or if it merely assists a conventional trigger return spring. Evidence regarding the forces involved and the function of any trigger return spring in the accused device could be relevant.
• Scope Questions: The infringement analysis may focus on the term "substantially in-battery position." The parties may dispute the precise point in the bolt carrier's forward travel at which the accused locking bar is moved out of the blocking position and whether this timing falls within the scope of the claim term as construed by the court.

’003 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a safety selector adapted to be mounted in a fire control mechanism pocket of a receiver to pivot between safe, standard semiautomatic, and forced reset semiautomatic positions,	The device includes a safety selector that is mounted in a receiver pocket and pivots between safe, standard, and forced reset modes. The complaint includes a photograph of the accused device's components, with an arrow pointing to the "Safety Selector" alleged to enable mode switching. (Compl. p. 15).	¶44	col. 12:30-34
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...	In the standard mode, rearward movement of the bolt carrier causes the disconnector hook to catch the hammer hook, requiring a manual trigger release to fire again.	¶44	col. 12:35-43
whereupon in said forced reset semiautomatic 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.	In the forced reset mode, the safety selector prevents the disconnector hook from catching the hammer hook, allowing the user to fire again upon the bolt carrier returning to battery without first manually releasing the trigger.	¶44	col. 12:44-50

Identified Points of Contention

• Technical Questions: An evidentiary question may be how the accused safety selector achieves the function of "preventing said disconnector hook from catching said hammer hook." The case may require a detailed mechanical analysis to determine if the selector physically blocks the disconnector's movement, repositions it, or uses another mechanism, and whether that mechanism meets the claim limitation.
• Scope Questions: The analysis may raise the question of whether the accused device's "standard semiautomatic" mode operates exactly as defined by the "whereupon" clause, specifically whether a user "must manually release said trigger member" to reset the hammer from the disconnector.

V. Key Claim Terms for Construction

• The Term: "forced to the set position" (’223 Patent, Claim 4; ’003 Patent, Claim 4)

  • Context and Importance: This term is central to the "forced reset" concept. Practitioners may focus on this term because its construction will determine the nature of the interaction required between the hammer and the trigger member. The dispute may concern whether this requires the hammer's action to be the sole resetting force or if it can merely assist a conventional trigger spring.
  • Intrinsic Evidence for a Broader Interpretation: The specification states that mechanical interference between the hammer and trigger "forces the trigger to pivot... toward and to its reset position" (’223 Patent, col. 5:32-37), which could suggest that any non-user-initiated force compelling the reset meets the limitation.
  • Evidence for a Narrower Interpretation: The background distinguishes the invention from standard triggers where a user must "allow the trigger to return to its reset state" for a spring to act (’223 Patent, col. 1:24-32). A defendant may argue that "forced" implies a mechanism powerful enough to reset the trigger even against sustained user finger pressure, distinguishing it from a spring-assisted reset that occurs upon relaxation of that pressure.

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

  • Context and Importance: This term defines the critical safety timing for when the locking bar unblocks the trigger, permitting the next shot. The case's outcome may depend on whether the accused device's unlocking timing falls within the court's interpretation of "substantially."
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the purpose of the locking bar is to prevent "'hammer follow' against the bolt carrier assembly" (’223 Patent, col. 5:48-49). This could support a reading where any point late enough in the cycle to prevent this malfunction is "substantially" in-battery.
  • Evidence for a Narrower Interpretation: The specification also states the mechanism "prevents early release of the hammer... before the bolt is completely locked and in-battery" (’223 Patent, col. 5:65-6:2). This language could be cited to support a narrower construction requiring the bolt's locking lugs to be fully engaged before the trigger can be released.

VI. Other Allegations

• Indirect Infringement: While the formal counts are for direct infringement, the complaint alleges that individual defendant William C. King Jr. "directed Cloak to infringe the Plaintiffs' patent rights" (Compl. ¶32), which contains language suggestive of induced infringement.
• Willful Infringement: The complaint alleges willful infringement based on Defendants’ alleged pre-suit knowledge of the asserted patents. This knowledge is purportedly evidenced by a "Legal Library" webpage on the website of "Partisan Triggers," the alleged manufacturer of the accused device, which links to copies of the ’223, ’003, and ’336 patents (Compl. ¶¶ 30-31, 33).

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

• A central issue will be one of mechanical function: Does the accused "Partisan Disruptor" operate using the specific sequence of interactions claimed in the patents—particularly the hammer forcing the trigger to reset and the safety selector preventing disconnector engagement—or does it achieve a similar result through a mechanism that is technically distinct from that which is claimed?
• A key question of claim construction will involve the temporal scope of "substantially in-battery position." The viability of the infringement claim may depend on whether the precise timing of the accused device's locking bar disengagement is found to occur within the bounds of this critical safety-related limitation.
• A significant factual question for willfulness will be one of imputed knowledge: Can Plaintiffs demonstrate that the presence of patents in a "Legal Library" on a manufacturer's website is sufficient to establish that the downstream reseller (Defendant Cloak Industries) and its principal had the requisite knowledge of infringement to support a finding of willfulness?