DCT

4:26-cv-00018

ABC IP LLC v. Webcorp Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-00018, E.D. Mo., 01/07/2026
  • Venue Allegations: Plaintiffs allege venue is proper because Defendants reside in or have committed acts of infringement within the district and have a regular and established place of business there.
  • Core Dispute: Plaintiffs allege that Defendants’ "Atrius Forced Reset Selector" and "Partisan Disruptor" firearm trigger mechanisms infringe six patents related to forced reset trigger technology.
  • Technical Context: The technology at issue involves "forced reset triggers" for semi-automatic firearms, which use the energy from the reciprocating bolt carrier to mechanically reset the trigger, enabling a faster potential rate of fire than standard trigger mechanisms.
  • Key Procedural History: The complaint alleges that Defendants had pre-suit knowledge of the asserted patents based on a 2024 conversation between principals of Plaintiff ABC and Defendant Kirgin, which forms the basis for the willfulness allegations.

Case Timeline

Date Event
2017-09-29 Earliest Priority Date for U.S. Patent No. 10,514,223
2019-12-24 U.S. Patent No. 10,514,223 Issued
2021-11-05 Earliest Priority Date for U.S. Patent No. 12,031,784
2022-01-10 Earliest Priority Date for U.S. Patent Nos. 11,724,003, 12,036,336, and 12,274,807
2022-09-08 Earliest Priority Date for U.S. Patent No. 12,038,247
2023-08-15 U.S. Patent No. 11,724,003 Issued
2024-07-09 U.S. Patent No. 12,031,784 Issued
2024-07-16 U.S. Patent No. 12,038,247 Issued
2024-07-16 U.S. Patent No. 12,036,336 Issued
2025-04-15 U.S. Patent No. 12,274,807 Issued
2026-01-07 Complaint Filed

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 addresses the desire among some firearm users to increase the rate of semi-automatic fire, noting that standard trigger mechanisms, which require a user to manually release and reset the trigger, limit this rate (’247 Patent, col. 1:26-40).
  • The Patented Solution: The invention is a trigger mechanism featuring a pivoting cam that interacts with both the trigger member and the reciprocating bolt carrier. In a "forced reset" mode, rearward movement of the bolt carrier pivots the cam, which in turn forces the trigger member back to its reset position. A three-position safety selector allows the user to switch between this forced reset mode, a standard semi-automatic mode that uses a disconnector, and a safe mode (’247 Patent, Abstract).
  • Technical Importance: This design provides a selectable, "drop-in" system to increase the potential rate of fire in standard AR-pattern firearms without requiring modification to other major components like the bolt carrier (’247 Patent, col. 2:48-52).

Key Claims at a Glance

  • The complaint asserts independent Claim 15 (Compl. ¶53).
  • Essential elements of Claim 15 include:
    • A firearm trigger mechanism comprising: a hammer, a trigger member, a disconnector, a cam, and a safety selector.
    • The safety selector is adapted to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions.
    • In the standard semi-automatic mode, the disconnector catches the hammer, requiring manual trigger release to reset.
    • In the forced reset mode, rearward movement of the bolt carrier causes the cam to force the trigger member to its set position.
    • In the forced reset mode, the safety selector prevents the disconnector hook from catching the hammer hook.

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

The Invention Explained

  • Problem Addressed: A forced reset trigger's locking member, designed for one firearm platform (e.g., an AR-15), may have a geometry that interferes with the bolt carrier of a different platform (e.g., an AR-10). A locking member tall enough to be actuated by the AR-10 bolt carrier might be struck and damaged by the AR-10's lower-sitting forward section during rearward cycling (’784 Patent, col. 1:20-44).
  • The Patented Solution: The invention discloses a locking member with an "upwardly extending deflectable portion that is separately movable relative to the body portion." This allows the extension to be rigid when pushed from the rear by the bolt carrier returning to battery (to unlock the trigger), but to fold or pivot away when struck from the front by the bolt carrier cycling to the rear, thus avoiding interference (’784 Patent, col. 2:1-6; Abstract).
  • Technical Importance: This design enhances the cross-platform compatibility of a forced reset trigger mechanism, allowing a single design to function in firearms with different bolt carrier dimensions (’784 Patent, col. 1:5-12).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 4 (Compl. ¶¶63, 65).
  • Essential elements of Claim 1 include:
    • In a forced reset trigger mechanism, an extended trigger member locking device comprising a locking member.
    • The locking member is movable between a first (locked) and second (unlocked) position.
    • The locking member has a body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion."

U.S. Patent No. 10,514,223 - *“Firearm Trigger Mechanism,”* issued Dec. 24, 2019

  • Technology Synopsis: The patent describes a trigger mechanism for increasing the rate of semi-automatic fire. The technical problem is the limitation of standard triggers that require manual reset (’223 Patent, col. 1:20-40). The solution involves a mechanism where the cycling of the bolt carrier forces the hammer rearward, and the hammer in turn makes contact with the trigger member, forcing it to its set position, while a locking bar prevents premature firing until the bolt is in battery (’223 Patent, Abstract; Compl. ¶27).
  • Asserted Claims: Independent Claim 4 (Compl. ¶70).
  • Accused Features: The complaint alleges that the "Partisan Disruptor" trigger includes a hammer, trigger member, and locking bar that perform these forced reset and locking functions (Compl. ¶¶44, 72).

U.S. Patent No. 11,724,003 - *“Firearm Trigger Mechanism,”* issued Aug. 15, 2023

  • Technology Synopsis: This patent discloses a trigger mechanism that builds upon the forced reset concept by adding selectable modes of operation. The invention provides a three-position safety selector that allows the user to choose between a safe position, a standard semi-automatic mode utilizing a disconnector, and a forced reset semi-automatic mode where the disconnector is disabled (’003 Patent, Abstract; Compl. ¶28).
  • Asserted Claims: Independent Claim 4 (Compl. ¶78).
  • Accused Features: The complaint accuses the "Partisan Disruptor," which is marketed with "Safe, Semi-Automatic, and Enhanced Semi-Automatic modes," of infringing this patent (Compl. ¶¶44, 47, p. 13).

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

  • Technology Synopsis: This patent describes a trigger mechanism with selectable modes similar to the ’003 Patent. The safety selector is configured such that when it is in the forced reset mode, it "causes said disconnector to be repositioned and in doing so prevents said disconnector hook from catching said hammer hook" (’336 Patent, Abstract; Compl. ¶28). This mechanical disabling of the disconnector is a key feature of the forced reset mode.
  • Asserted Claims: Independent Claim 3 (Compl. ¶85).
  • Accused Features: The complaint alleges the "Partisan Disruptor" and its three-position selector infringe by implementing this selectable, disconnector-disabling functionality (Compl. ¶¶44, 86).

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

  • Technology Synopsis: This patent also describes a trigger mechanism with safe, standard semi-automatic, and forced reset semi-automatic modes, controlled by a three-position safety selector. The claims detail the sequence of operations in both the standard mode (where the disconnector catches the hammer) and the forced reset mode (where the selector prevents the disconnector from catching the hammer) (’807 Patent, Abstract; Compl. ¶28).
  • Asserted Claims: Independent Claim 1 (Compl. ¶92).
  • Accused Features: The complaint alleges the three-mode functionality of the "Partisan Disruptor" infringes this patent (Compl. ¶¶44, 93).

III. The Accused Instrumentality

Product Identification

The complaint names two accused instrumentalities: the (3-Position) “Atrius Forced Reset Selector” (“First Infringing Device”) and the (3-Position) “Partisan Disruptor” (“Second Infringing Device”) (Compl. ¶¶30, 44).

Functionality and Market Context

  • The Atrius Forced Reset Selector is marketed as a "three-position selector" for AR-15 platforms that provides "SAFE, SEMI (traditional), and SUPER-SEMI" modes (Compl. ¶33, p. 8). The product description states it allows the user to "force the reset" of the trigger for a faster rate of fire and is sold as a standalone component, in conjunction with other parts, or pre-installed in a firearm (Compl. ¶32).
  • The Partisan Disruptor is marketed as a "three-position safety selector with Safe, Semi-Automatic, and Enhanced Semi-Automatic modes" and is described as a "Forced Reset Trigger" (Compl. ¶47, p. 13). It is sold as a standalone product or pre-installed in a firearm or receiver (Compl. ¶46).
  • The complaint provides plaintiff-generated renderings of the Atrius selector, one of which is a color-coded diagram illustrating the alleged interaction between the selector cam, hammer, trigger, and disconnector (Compl. ¶54, p. 16). For the Partisan Disruptor, the complaint includes product photographs with labels pointing to components such as the "Locking bar" and "Pivot" (Compl. ¶72, p. 29).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
A firearm trigger mechanism comprising: a hammer having a sear catch and a hook for engaging a disconnector... The Atrius selector is installed with a hammer that has a sear catch and a hook for engaging a disconnector. ¶54 col. 4:12-26
a trigger member having a sear... The Atrius selector is installed with a trigger member that has a sear. ¶54 col. 3:51-64
a disconnector having a hook for engaging said hammer... The system includes a disconnector adapted to pivot and having a hook for engaging the hammer. ¶54 col. 4:27-32
a cam having a cam lobe... The Atrius selector has a cam and lever. ¶54 col. 4:33-47
a safety selector adapted to be mounted in a fire control mechanism pocket... to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions, The user can switch the Atrius selector between safe, standard semiautomatic, and forced reset semiautomatic modes. ¶¶34-35 col. 5:10-23
whereupon in said forced reset semi-automatic position... said safety selector preventing said disconnector hook from catching said hammer hook... In the forced reset mode, the cam both forces the reset of the trigger and locks it during operation. The complaint alleges this mode of operation functions as claimed. ¶54 col. 9:1-11
  • Identified Points of Contention:
    • Functional Questions: A primary question may be whether the "SUPER-SEMI" mode of the accused Atrius selector operates by having the safety selector prevent the disconnector from catching the hammer, as required by the claim. The analysis will likely focus on the precise mechanical interactions between the selector, the cam, and the disconnector in this mode. The complaint's visual evidence, showing a rendering of these parts interacting, suggests this will be a central point of proof (Compl. ¶54, p. 16).

’784 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
In a forced reset trigger mechanism, an extended trigger member locking device, comprising: a locking member that is movable between a first position in which it locks a trigger... and a second position... The Atrius selector functions as a locking member and has a first, locked position and a second, unlocked position. ¶64 col. 3:1-21
the locking member configured to be movably supported by a frame The Atrius selector is movably supported by the firearm's lower receiver (frame). ¶64 col. 3:22-26
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, The Atrius selector has an upward extending lever arm configured to make contact with the bolt carrier. ¶64 col. 3:34-40
the locking member having a body portion that is movably supported and an upwardly extending deflectable portion that is separately movable relative to the body portion... The complaint does not provide sufficient detail for analysis of this element, stating only that the Atrius Super Selektor "operates as a locking member" and has an "upward extending portion" (Compl. ¶64). ¶64 col. 3:34-47
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis for the ’784 Patent will likely turn on the construction of "deflectable portion that is separately movable relative to the body portion." The core question will be whether the accused Atrius selector's locking arm is a single, rigid piece or if it incorporates a distinct, separately movable or hinged component that meets this claim limitation. The complaint's assertion of dependent Claim 4, which specifies the deflectable portion "pivots," suggests this structural feature is a key aspect of the infringement theory (Compl. ¶65).

V. Key Claim Terms for Construction

’247 Patent: "safety selector preventing said disconnector hook from catching said hammer hook" (Claim 15)

  • Context and Importance: This phrase describes the essential function of the "forced reset" mode, distinguishing it from the "standard semi-automatic" mode. Proving infringement will require showing that the accused device's "SUPER-SEMI" mode achieves this specific mechanical prevention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Parties may argue that the claim uses functional language, potentially covering any mechanism where rotating the selector to the third position results in the disconnector being prevented from engaging the hammer, regardless of the precise interaction.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where a "narrow semi-circular portion 116" of the safety selector physically obstructs the disconnector, preventing it from pivoting with the trigger (’247 Patent, col. 8:30-39). Parties may argue the claim should be construed to require this direct physical blocking by a feature on the selector.

’784 Patent: "deflectable portion that is separately movable relative to the body portion" (Claim 1)

  • Context and Importance: This term defines the novel structure of the locking member intended to provide cross-platform compatibility. The infringement case hinges on whether the accused product possesses this specific two-part, articulated structure.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification contemplates that the extension portion "could be made from a resilient material configured to deflectably bend" (’784 Patent, col. 3:45-48), which may support an argument that "separately movable" does not strictly require a separate component attached by a pin.
    • Evidence for a Narrower Interpretation: The primary embodiment shows a distinct body portion (26) and extension portion (22) connected by a pivot pin (24), and the claim language "separately movable" suggests two distinct elements (’784 Patent, Fig. 2). The Abstract also states the extension is "separately movable," reinforcing the idea of distinct parts.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both contributory and induced infringement of the ’247 Patent. Inducement is based on allegations that Defendants instruct customers to assemble the standalone "Atrius" selector with other firearm components to create an infringing combination (Compl. ¶56). Contributory infringement is based on allegations that the selector is a material part of the invention, is especially made for an infringing use, and is not a staple article of commerce (Compl. ¶55).
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents. The basis for willfulness is alleged pre-suit knowledge stemming from a 2024 conversation in which Plaintiffs' principals allegedly discussed the Asserted Patents with Defendant Kirgin (Compl. ¶21, 43, 60, 67, 75, 82, 89, 96).

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

  • A core issue will be one of structural interpretation: Can the claim term "deflectable portion that is separately movable" in the ’784 Patent be construed to read on the physical structure of the accused "Atrius Forced Reset Selector's" locking arm? The case may turn on whether this requires a multi-part, hinged component or if it can cover other designs.
  • A key evidentiary question will be one of operational equivalence: Does the "SUPER-SEMI" mode of the accused "Atrius" selector and the "Enhanced Semi-Automatic" mode of the "Partisan Disruptor" function by having the safety selector mechanically prevent the disconnector from engaging the hammer, as required by the claims of the ’247 patent family, or is there a fundamental mismatch in their technical operation?