DCT
3:25-cv-00454
ABC IP LLC v. Kline
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
- Defendant: Jesse T. Kline (Mississippi)
- Plaintiff’s Counsel: Mockbee Ellis, P.A. (Local Counsel); Wood Herron & Evans LLP
- Case Identification: 3:25-cv-00454, S.D. Miss., 06/23/2025
- Venue Allegations: Venue is based on the Defendant’s alleged residence and/or regular and established place of business within the Southern District of Mississippi.
- Core Dispute: Plaintiffs allege that Defendant’s sale of "3-Position 'Super Safety'" kits for AR-pattern firearms constitutes contributory and induced infringement of a patent related to a selectable, mechanically forced-reset trigger mechanism.
- Technical Context: The technology concerns firearm trigger mechanisms that use the energy from a cycling bolt carrier to mechanically reset the trigger, enabling a faster rate of fire than is possible with a standard semi-automatic trigger.
- Key Procedural History: The complaint identifies Plaintiff ABC IP, LLC as the patent’s assignee and Plaintiff Rare Breed Triggers, Inc. as its exclusive licensee. No other significant procedural history, such as prior litigation or administrative proceedings involving the patent-in-suit, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2022-09-08 | '247 Patent Priority Date |
| 2024-05-02 | Defendant allegedly offers Accused Product for sale |
| 2024-07-16 | '247 Patent Issue Date |
| 2025-06-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,038,247 - "FIREARM TRIGGER MECHANISM"
- Patent Identification: U.S. Patent No. 12,038,247, "FIREARM TRIGGER MECHANISM," issued July 16, 2024.
The Invention Explained
- Problem Addressed: The patent seeks to provide an improved trigger mechanism for increasing the rate of fire in semi-automatic firearms (Compl. ¶15; '247 Patent, col. 1:11-14). Standard triggers require the user to manually release the trigger to reset the firing mechanism, which limits firing speed, while some prior art forced-reset designs required modification to other core components like the bolt carrier ('247 Patent, col. 1:26-42, col. 1:60-63).
- The Patented Solution: The invention is a "drop-in" trigger module that offers three modes: safe, standard semi-automatic, and forced reset semi-automatic ('247 Patent, col. 2:23-29). The key component is a pivoting cam that is acted upon by the firearm's reciprocating bolt carrier. In forced-reset mode, the bolt carrier's rearward movement pivots the cam, which in turn physically forces the trigger member back to its reset position, preparing it for the next shot without the user needing to fully release the trigger ('247 Patent, Abstract; col. 2:55-65).
- Technical Importance: The design provides a selectable forced-reset capability in a self-contained module, compatible with standard AR-pattern firearms and bolt carriers, offering an alternative to prior art that required more extensive firearm modification (Compl. ¶15; '247 Patent, col. 2:17-26).
Key Claims at a Glance
- The complaint asserts independent Claim 15 (Compl. ¶32).
- Essential elements of Claim 15 include:
- A hammer, a trigger member with a sear, and a disconnector, all adapted for a firearm's fire control pocket.
- A movable cam with a cam lobe.
- A "standard semi-automatic mode" where the cam is in a first position and the disconnector functions normally to catch the hammer after a shot, requiring a manual trigger release to reset.
- A "forced reset semi-automatic mode" where the cam is in a second position, causing the bolt carrier's movement to force the trigger member to its set position, while the disconnector hook is "prevented from catching said hammer hook."
III. The Accused Instrumentality
Product Identification
The accused products are "3-Position 'Super Safety'" kits, allegedly sold by the Defendant under the alias "Maserati Mike" or "Maserati Mikey" (Compl. ¶¶4, 21).
Functionality and Market Context
The complaint alleges these are kits containing components of a patented apparatus which, when assembled as intended, create an infringing trigger mechanism (Compl. ¶¶24, 29). The functionality is alleged to mirror the patent’s claims, providing a standard semi-automatic mode and a "forced reset semiautomatic with cam modes" (Compl. ¶27). The complaint provides a screenshot of an alleged social media post offering "17-4 heat Treated, blasted, and will come polished 3D printed kits" for sale, which suggests the products are marketed to firearm enthusiasts as component parts (Compl. ¶22, p. 5). This screenshot from a Facebook group titled "Hoffman Super Safety & FRT Tips/Tricks/Show" depicts piles of small, machined metal parts consistent with firearm trigger components (Compl. ¶22, p. 5).
IV. Analysis of Infringement Allegations
'247 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a hammer having a sear catch and a hook for engaging a disconnector and adapted to be mounted in a fire control mechanism pocket of a receiver... | The Infringing Device is installed in a fire control mechanism pocket and includes a hammer with a sear catch and a hook for engaging a disconnector. A diagram shows the bolt carrier interacting with the hammer. | ¶33, p. 8 | col. 7:49-51 |
| a trigger member having a sear and adapted to be mounted in the fire control mechanism pocket to pivot... | The Infringing Device includes a trigger member with a sear that pivots between set and released positions. | ¶33, p. 9 | col. 7:55-56 |
| said disconnector having a hook for engaging said hammer and adapted to be mounted in the fire control mechanism pocket... | The Infringing Device includes a disconnector with a hook adapted to engage the hammer. | ¶33, p. 10 | col. 8:1-2 |
| 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 has a cam with a cam lobe that is movable between two positions, where the second position forces the trigger member toward its set position. A diagram shows the cam in these two positions. | ¶33, p. 10-11 | col. 8:6-8; col. 9:49-52 |
| 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 the standard mode, the cam is in a first position, and the disconnector hook catches the hammer hook. | ¶33, p. 11-12 | col. 9:13-14 |
| 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 the forced reset mode, the cam is moved to a second position, and the disconnector hook "doesn't catch the hammer hook." | ¶33, p. 12 | col. 9:33-35 |
Identified Points of Contention
- Scope Questions: Claim 15 requires that in the forced reset mode, the "disconnector hook is prevented from catching said hammer hook." The patent specification discloses that this "prevention" is achieved by a specific portion of the safety selector physically blocking the disconnector from pivoting ('247 Patent, col. 8:58-63). A central question will be whether the accused "Super Safety" kits achieve this prevention in the same manner. The infringement analysis may hinge on whether the claim term "prevented" is limited to the specific blocking mechanism shown or can be construed more broadly to cover any means of disabling the disconnector’s catch function.
- Technical Questions: The complaint asserts indirect infringement, alleging the defendant sells kits and "instructs purchasers to assemble" them into an infringing device (Compl. ¶¶ 26, 35). A key evidentiary question for the court will be what proof exists of such instructions. The case may turn on evidence demonstrating the defendant’s knowledge and specific intent for the components to be assembled and used in an infringing manner, as required for induced and contributory infringement.
V. Key Claim Terms for Construction
- The Term: "prevented from catching"
- Context and Importance: This phrase captures the essential functional difference between the patented invention's "standard" and "forced reset" modes as claimed in Claim 15. The interpretation of how this "prevention" is achieved will be critical to the infringement analysis, as it defines a core aspect of the forced-reset operation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may argue the term should be given its plain and ordinary meaning, covering any mechanism—whether by physical blocking, spatial relationship, or other interaction—that stops the disconnector hook from engaging the hammer hook when the device is in forced-reset mode.
- Evidence for a Narrower Interpretation: The specification describes a specific structural basis for this function: "a narrow semi-circular portion 116 [of the safety selector]...prevents the disconnector 60 from pivoting...thus preventing the disconnector hook 64 from catching the hammer hook 53" ('247 Patent, col. 8:58-63). A defendant may argue this language limits the claim to an apparatus where the safety selector itself directly causes the prevention, potentially excluding other methods of disabling the disconnector.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both contributory and induced infringement (Compl. ¶31). The basis for contributory infringement is the allegation that the defendant sells components "especially made or especially adapted for use in an infringement" that are not a "staple article or commodity of commerce suitable for substantial noninfringing use" (Compl. ¶24). The basis for induced infringement is the allegation that the "Defendant instructs its customers to assemble the components it sells into an infringing combination of parts" (Compl. ¶35).
- Willful Infringement: The complaint alleges that the Defendant "knew of the ’247 Patent and knew or should have known that his acts infringed," and that the infringement is therefore willful (Compl. ¶14, 38). This allegation is made upon "information and belief" and does not specify whether the alleged knowledge was pre- or post-suit.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of indirect liability: As the defendant is accused of selling kits, the case will likely depend on what evidence Plaintiffs can produce to demonstrate not only that the assembled kits infringe, but that the defendant specifically intended and took affirmative steps to encourage this infringing assembly, as required to prove induced infringement.
- The case will also turn on a question of claim scope: The court will need to determine whether the term "prevented from catching," as used in Claim 15, is limited to the specific safety-selector-blocking mechanism described in the patent's embodiment or if it can be read more broadly. The outcome of this construction will be critical in determining whether the accused device's specific operational method falls within the scope of the patent.