ABC IP LLC v. Orion Arms Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Orion Arms Corp. d/b/a, Orion Wholesale (Indiana)
  • Plaintiff’s Counsel: Wood Herron & Evans LLP; Fish & Richardson P.C.
• Case Identification: 4:26-cv-00032, S.D. Ind., 02/04/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Indiana because Defendant has committed acts of infringement and maintains a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendant’s "Atrius Forced Reset Selector" infringes two patents related to firearm trigger mechanisms designed to accelerate the rate of semiautomatic fire.
• Technical Context: The technology concerns "forced reset triggers" for AR-platform firearms, which use the energy from the cycling bolt carrier to mechanically reset the trigger, enabling a faster firing sequence than is possible with standard trigger mechanisms.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history involving the asserted patents.

Case Timeline

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

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

• Patent Identification: U.S. Patent No. US12038247B2, "Firearm Trigger Mechanism," issued July 16, 2024 (the "'247 Patent").

The Invention Explained

• Problem Addressed: The patent's background describes a desire among shooters to increase the rate of semiautomatic fire, which is limited in standard mechanisms by the need for a user to manually release the trigger to allow the sear to reset after each shot '247 Patent, col. 1:17-49
• The Patented Solution: The invention is a trigger mechanism, selectable between a standard semiautomatic mode and a "forced reset" mode. In the forced reset mode, the rearward movement of the firearm's bolt carrier pivots a cam, which in turn physically forces the trigger member back to its reset position '247 Patent, abstract; '247 Patent, col. 2:55-67 This mechanical reset obviates the need for the user to manually release the trigger, allowing for a more rapid firing sequence '247 Patent, abstract
• Technical Importance: This approach provides a "drop-in" module that allows a user to select between a conventional semiautomatic firing mode and a mechanically accelerated firing mode using a single selector switch Compl. ¶18

Key Claims at a Glance

• The complaint asserts independent Claim 15 Compl. ¶26
• Claim 15 recites a firearm trigger mechanism comprising:
  • A hammer with a sear catch and a hook for a disconnector.
  • A trigger member with a sear.
  • A disconnector with a hook for engaging the hammer.
  • A cam with a cam lobe, movable between a first and second position.
  • The claim further specifies the interactions of these components in two distinct modes: a "standard semi-automatic mode" where the disconnector catches the hammer and requires a manual trigger release, and a "forced reset semi-automatic mode" where the cam is in a second position and the disconnector hook is prevented from catching the hammer hook.
• The complaint reserves the right to assert other claims Compl. ¶26

U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger"

• Patent Identification: U.S. Patent No. US12031784B1, "Adapted Forced Reset Trigger," issued July 9, 2024 (the "'784 Patent").

The Invention Explained

• Problem Addressed: The patent's background explains that prior art forced reset triggers designed for one firearm pattern (e.g., AR-15) may not be operable in a geometrically different pattern (e.g., AR-10). Specifically, a locking bar long enough to be actuated by the AR-10's bolt carrier would interfere with the carrier as it cycles rearward '784 Patent, col. 1:21-44
• The Patented Solution: The invention provides a trigger locking member with a "deflectable extension" that functions as a one-way hinge. The extension is rigid when pushed from the rear by the bolt carrier (to unlock the trigger), but it deflects or folds out of the way when the bolt carrier moves over it from the front during its rearward cycle '784 Patent, abstract; '784 Patent, col. 1:46-52 This design allows the locking member to be actuated without causing interference, accommodating geometric variations between firearm platforms '784 Patent, col. 2:31-39
• Technical Importance: This solution aims to create a more versatile forced reset trigger mechanism that can be used in a wider variety of semiautomatic firearms without modification '784 Patent, col. 1:5-11

Key Claims at a Glance

• The complaint asserts independent Claim 1 Compl. ¶40
• Claim 1 recites an extended trigger member locking device for a forced reset trigger mechanism, comprising:
  • A locking member movable between a first position (locking the trigger) and a second position (not restricting the trigger).
  • The locking member is configured to be moved from the first to the second position by "actuating contact with a surface of a bolt carrier."
  • The locking member has a "movably supported" body portion.
  • The locking member also has an "upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position."
• The complaint reserves the right to assert other claims Compl. ¶40

III. The Accused Instrumentality

Product Identification

• The "Three-Position 'Atrius Forced Reset Selector'," also referred to as the "Atrius Super Selector" Compl. ¶21 The complaint notes it is offered in a single lever version and an ambidextrous lever version Compl. ¶23

Functionality and Market Context

• The complaint alleges the accused device is a trigger mechanism component for AR-15 pattern firearms Compl. ¶29 It is alleged to allow a user to switch between three modes of operation: safe, standard semiautomatic (disconnector mode), and forced reset semiautomatic (cam mode) by rotating a selector switch Compl. ¶24 The complaint includes a screenshot from Defendant's website showing the product marketed as an "ATRIUS DEVELOPMENT 3 POSITION FORCED RESET SELECTOR COMPATIBLE W/ MILSPEC AR-15" Compl. p. 6

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

• Identified Points of Contention:
  • Functional Questions: The complaint relies heavily on color-coded diagrams to show the alleged function. A key question for the court will be whether the Accused Product's components actually operate and interact in the precise sequence claimed for both the "standard" and "forced reset" modes. The allegation that the disconnector is "prevented" from catching the hammer hook in forced reset mode will be a focal point of technical discovery.

’784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute may center on the meaning of "separately movable." The patent describes a "one-way hinge feature" '784 Patent, col. 1:66, which may suggest a narrower scope than the plain language of the claim. The case will question whether the alleged hinged movement of the accused selector's lever arm falls within the proper construction of "separately movable relative to the body portion."
  • Technical Questions: Evidence will be needed to determine if the accused selector's lever arm is merely "deflectable" (implying material flex) or if it is "separately movable" via a distinct mechanical pivot, as alleged in the complaint and required by the claim.

V. Key Claim Terms for Construction

For the ’247 Patent

• The Term: "prevented from catching" (Claim 15)
• Context and Importance: This term is central to distinguishing the "forced reset" mode from the "standard" mode. The infringement analysis depends on whether the accused device, in one of its modes, actively "prevents" the disconnector-hammer interaction, or if that interaction simply does not occur for other reasons.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language does not specify the mechanism of prevention, which could support a construction covering any configuration where the catch does not happen.
  • Evidence for a Narrower Interpretation: The specification links the prevention to the action of the safety selector: "...in the forced reset semi-automatic position, the disconnector 60 is 'disabled' in that the disconnector hook 64 is unable to catch the hammer hook 53" '247 Patent, col. 8:60-63 This suggests the "prevention" is an affirmative blocking action by the selector, potentially narrowing the term's scope.

For the ’784 Patent

• The Term: "separately movable" (Claim 1)
• Context and Importance: This term defines the core novelty of the patent—the two-piece nature of the locking member. The infringement case hinges on whether the accused device's hinged lever arm constitutes a portion that is "separately movable" from its body.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "separately movable" could be argued to encompass any two components that can move relative to one another, including via a hinge.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the invention as having a "one-way hinge feature" and a "foldable extension portion" '784 Patent, col. 1:66-col. 2:2; '784 Patent, col. 3:39-44 The specific embodiments shown in Figures 2-4 and 8-10 all depict a distinct part pivoting relative to the body, which may be used to argue for a construction limited to such hinged or pivoted arrangements.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for both patents, asserting that Defendant encourages and instructs customers to install and use the accused device in an infringing manner through its website and promotional materials Compl. ¶¶29, 43 Contributory infringement is also alleged, on the basis that the accused device is a material part of the patented invention, is specially designed for use in an infringing system, and is not a staple article of commerce suitable for substantial noninfringing use Compl. ¶¶31, 45
• Willful Infringement: The complaint alleges that Defendant "has known or should have known" that its actions constituted infringement and that it continued its infringing activities despite this knowledge, rendering the infringement willful Compl. ¶¶14, 32, 46

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

The resolution of this case may depend on the court's answers to several key questions:

1. A central issue will be one of definitional scope: Can the claim term "separately movable" in the ’784 Patent be construed broadly to cover any relative motion, or is its meaning limited by the specification's embodiments to a distinct, hinged component that pivots independently of the main body's movement?
2. A key evidentiary question will be one of technical operation: For the ’247 Patent, does the accused device's safety selector, when in the "forced reset" mode, perform the specific function of "preventing" the disconnector from catching the hammer, as required by the claim, and does the device's cam system otherwise operate in the precise manner claimed?
3. A final question will concern knowledge and intent: Assuming infringement is found, what evidence will demonstrate that the Defendant knew of the patents and the infringing nature of its products, which is necessary to support the claims for willful and indirect infringement?