ABC IP LLC v. Optics Planet Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Optics Planet, Inc. d/b/a OpticsPlanet (Illinois)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 1:26-cv-01072, N.D. Ill., 01/29/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant has a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s aftermarket firearm trigger mechanisms, which feature a "forced reset" capability, infringe six U.S. patents related to selectable, forced reset trigger technology for semiautomatic firearms.
• Technical Context: The technology concerns firearm trigger mechanisms that use the energy from a firearm's cycling action to mechanically reset the trigger, which can allow for an accelerated rate of semiautomatic fire compared to standard trigger designs.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

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 describes a desire among some shooters to increase the rate of semiautomatic fire, but notes that existing solutions can be complex, expensive, require significant practice, or necessitate modified firearm components beyond the trigger mechanism itself ’247 Patent, col. 1:16-2:15
• The Patented Solution: The invention is a trigger mechanism that can be selected to operate in either a standard semiautomatic mode or a "forced reset" mode. In the forced reset mode, a cam, which is pivoted by the rearward movement of the firearm's bolt carrier, forces the trigger member back to its reset position ’247 Patent, col. 2:16-52 This allows a user to fire another round as soon as the bolt carrier returns to battery without needing to manually release and reset the trigger ’247 Patent, col. 10:4-12
• Technical Importance: The invention purports to provide a "drop-in" trigger module with a selectable forced reset function that does not require modification to other standard firearm components like the bolt carrier ’247 Patent, col. 2:16-24

Key Claims at a Glance

• The complaint asserts independent Claim 15 Compl. ¶38
• Essential elements of Claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
  • The cam is movable between a first position (for standard semi-automatic mode) and a second position (for forced reset mode).
  • In standard mode, the cam is in the first position, and the disconnector hook catches the hammer hook after a shot is fired.
  • In forced reset mode, the cam is in the second position, where its lobe forces the trigger member towards its set position, and the disconnector hook is prevented from catching the hammer hook.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger," issued July 9, 2024

The Invention Explained

• Problem Addressed: The patent notes that forced reset trigger mechanisms using a locking bar, such as the one described in U.S. Patent No. 10,514,223, may face geometric constraints in different firearm platforms. A locking bar extended to work with an AR-10's dimensions, for example, could interfere with the bottom of the bolt carrier as it cycles rearward ’784 Patent, col. 1:20-44
• The Patented Solution: The invention is an extended trigger member locking device featuring an "upwardly extending deflectable portion." This portion is rigid enough to be actuated by the bolt carrier upon returning to battery (unlocking the trigger), but it is designed to separately move, deflect, or fold away when contacted by the forward portion of the bolt carrier during its rearward cycle, thereby avoiding interference ’784 Patent, Abstract col. 2:1-6 A key embodiment shows this deflectable portion mounted on a separate pivot pin from the main body of the locking member ’784 Patent, Fig. 2
• Technical Importance: This design purports to adapt the forced-reset locking bar concept for compatibility with a wider range of semiautomatic firearm platforms that have different internal geometries and component spacing than a standard AR-15 ’784 Patent, col. 1:5-12

Key Claims at a Glance

• The complaint asserts independent Claim 1 Compl. ¶52
• Essential elements of Claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • A locking member movable between a first (locked) and second (unlocked) position.
  • The locking member has a movably supported body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion."
  • This deflectable portion moves between an extended position and a deflected position.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

Technology Synopsis

The patent describes a trigger mechanism where the hammer, when reset by the cycling bolt carrier, makes contact with the trigger member and forces it to its reset position. A pivotally mounted locking bar mechanically blocks the trigger from being pulled again until it is moved out of the way by the bolt carrier returning to a substantially in-battery position ’223 Patent, Abstract

Asserted Claims

Independent Claim 4 is asserted Compl. ¶66

Accused Features

The complaint alleges that the "Partisan Disruptor" (Second Infringing Device) infringes by incorporating a trigger mechanism with a housing, a hammer that forces the trigger to reset, and a locking bar that blocks the trigger until the bolt is in battery Compl. ¶¶31, 68

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

Technology Synopsis

The patent describes a trigger mechanism with a three-position safety selector for "safe," "standard semi-automatic," and "forced reset semi-automatic" modes. In the forced reset mode, the safety selector is configured to cause the disconnector to be repositioned, preventing it from catching the hammer and thereby enabling a forced reset cycle ’003 Patent, col. 3:54-col. 4:12

Asserted Claims

Independent Claim 4 is asserted Compl. ¶81

Accused Features

The complaint alleges the "Partisan Disruptor" infringes by including a three-position safety selector that operates to enable both standard semi-automatic and forced reset modes, with the selector preventing the disconnector from catching the hammer in the forced reset mode Compl. ¶¶31, 83

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

Technology Synopsis

This patent is similar to the ’003 patent, describing a trigger mechanism with a three-position safety selector for safe, standard semi-automatic, and forced reset modes. A key feature is that the safety selector, when in the forced reset position, "causes said disconnector to be repositioned and in doing so prevents said disconnector hook from catching said hammer hook" ’336 Patent, Abstract

Asserted Claims

Independent Claim 3 is asserted Compl. ¶96

Accused Features

The complaint alleges the "Partisan Disruptor" infringes by using a three-position safety selector that repositions the disconnector in the forced reset mode to prevent it from catching the hammer, thereby facilitating the forced reset function Compl. ¶¶31, 98

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

Technology Synopsis

This patent is also similar to the ’003 and ’336 patents, describing a trigger mechanism with a three-position safety selector. In the forced reset mode, the safety selector prevents the disconnector hook from engaging the hammer hook, enabling the trigger to be forced to its set position by the cycling of the bolt carrier ’807 Patent, Abstract

Asserted Claims

Independent Claim 1 is asserted Compl. ¶111

Accused Features

The complaint alleges the "Partisan Disruptor" infringes by using a three-position safety selector that prevents the disconnector from engaging the hammer in the forced reset mode, which is a required step for the forced reset cycle Compl. ¶¶31, 113

III. The Accused Instrumentality

Product Identification

• The complaint identifies two accused instrumentalities:
  1. The “Three-Position ‘Atrius Forced Reset Selector,’” also referred to as the “Atrius Super Selector” (the “First Infringing Device”) Compl. ¶27
  2. The “Partisan Disruptor” (the “Second Infringing Device”) Compl. ¶31

Functionality and Market Context

• The complaint alleges both devices are aftermarket trigger mechanisms for AR-15-pattern firearms Compl. ¶¶41, 69 A screenshot from Defendant's website shows the "Atrius Super Selektor" products offered for sale Compl., p. 7
• The Atrius Super Selector is alleged to provide the user with selectable modes of operation, including a standard semiautomatic mode with a disconnector and a forced reset semiautomatic mode Compl. ¶30
• The Partisan Disruptor is also alleged to be a trigger assembly with a three-position safety selector that allows the user to switch between safe, standard semiautomatic, and forced reset semiautomatic modes Compl. ¶33 In the forced reset mode, the cycling of the firearm's action is alleged to cause hammer contact that forcefully resets the trigger, while a locking bar prevents the trigger from being pulled until the bolt carrier has returned to battery Compl. ¶34

IV. Analysis of Infringement Allegations

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

U.S. Patent No. 12,031,784 Infringement Allegations

Identified Points of Contention

• Scope Questions: For the ’247 Patent, a central issue may be whether the "Atrius Super Selector" component functions as a "cam" with a "cam lobe" as those terms are understood in the patent. The analysis will question if the accused part's interaction with the trigger member constitutes the specific forcing action required by the claim.
• Technical Questions: For the ’784 Patent, the dispute may center on the "separately movable" limitation of the "deflectable portion." The complaint's allegations and diagrams suggest a distinct pivot mechanism. A key technical question will be what evidence demonstrates that the accused product's locking member contains a part that is truly "separately movable" from its main body, as opposed to being a single, flexible component.

V. Key Claim Terms for Construction

’247 Patent, Claim 15: "cam having a cam lobe"

• Context and Importance: This term is central to the mechanism of infringement for the '247 Patent. The definition of "cam" and "cam lobe" will determine whether the accused selector switch, which has multiple functions, performs the specific trigger-forcing action described in the claim. Practitioners may focus on this term because it distinguishes the invention from simple levers or other mechanical interactions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the function broadly, stating the cam lobe "forces the trigger member towards the set position" without necessarily limiting its shape ’247 Patent, col. 10:3-4 This functional language could support a broader definition covering any rotating part that achieves this result.
  • Evidence for a Narrower Interpretation: Figure 3 of the patent depicts the cam (110) with a distinct, rounded lobe (116). The description notes this specific structure. Arguments may arise that the term requires a structure with a specific profile designed to impart motion to a follower, consistent with a traditional mechanical definition of a cam.

’784 Patent, Claim 1: "upwardly extending deflectable portion that is separately movable relative to the body portion"

• Context and Importance: This phrase captures the asserted novelty of the ’784 Patent, which aims to solve a geometric interference problem. The interpretation of "separately movable" will be critical to determining infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "deflectable" could be interpreted to mean capable of bending. The claim language does not explicitly require a pivot pin or hinge, which could support a construction that reads on a single-piece, flexible component.
  • Evidence for a Narrower Interpretation: The phrase "separately movable relative to the body portion" suggests a multi-part construction. The patent's primary embodiment explicitly shows the deflectable portion (22) pivoting on a pin (24) that is distinct from the pivot for the main body (26), strongly supporting an interpretation that requires a discrete, articulated joint ’784 Patent, Fig. 2; col. 3:40-45

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement allegations are based on Defendant's promotional materials and instructions on its website, which allegedly encourage and instruct customers to install and use the accused products in an infringing manner (e.g., in an AR-15 firearm) Compl. ¶¶ 41, 55, 69, 84, 99, 114 Contributory infringement is alleged on the basis that the accused components are specially designed for use in a fire control unit to forcibly reset a trigger and are not suitable for substantial non-infringing use Compl. ¶¶ 43, 57, 72, 87, 102, 117
• Willful Infringement: The complaint alleges that Defendant engaged in "egregious infringement behavior with knowledge" of the asserted patents and that Defendant "has known or should have known" its actions constituted infringement Compl. ¶¶ 44, 58, 73, 88, 103, 118 The allegations appear to be based on post-issuance knowledge of the patents.

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

• A core issue will be one of technical operation: Does the "Atrius Super Selector" actually employ a "cam" that "forces" the trigger reset as claimed in the '247 patent, and does its locking member possess a "separately movable" portion as required by the '784 patent? The case may depend on factual evidence of how these accused products are constructed and operate, compared to the specific mechanisms described and claimed in the patents.
• A central question of claim scope will arise from the assertion of four different patents ('223, '003, '336, '807) against the "Partisan Disruptor." The litigation will need to resolve the precise boundaries of each patent's claims concerning the interaction between a locking bar, a disconnector, and a multi-position safety selector, and whether the accused product's single design falls within the scope of all four distinct claims.