DCT
1:25-cv-01192
ABC IP LLC v. As Designs LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rare Breed TRIGGERS, Inc. (Texas) and ABC IP, LLC (Delaware)
- Defendant: As Designs, LLC (North Carolina), Matthew S. Karlovic, Calvin Olson, and John Doe ("s3igu2"/"Seagoo Threetwo")
- Plaintiff’s Counsel: Rayburn Cooper & Durham, P.A.; Wood Herron & Evans LLP
- Case Identification: 1:25-cv-01192, M.D.N.C., 12/30/2025
- Venue Allegations: Venue is alleged to be proper as Defendants reside in and/or have a regular and established place of business in the Middle District of North Carolina.
- Core Dispute: Plaintiffs allege that Defendants’ "Super Safety" and "ARC-Fire" firearm trigger kits, and related components, infringe two patents related to selectable forced-reset trigger mechanisms.
- Technical Context: The technology concerns firearm trigger mechanisms that use the cycling of the bolt carrier to mechanically reset the trigger, allowing for a faster rate of semi-automatic fire than is possible with conventional designs.
- Key Procedural History: The complaint states that on August 9, 2025, Plaintiffs sent a cease and desist letter to Defendants AS Designs and Karlovic, identifying the ’247 Patent and accusing the "Super Safety" and "ARC-Fire" products of infringement. The complaint alleges Defendants ignored this demand.
Case Timeline
| Date | Event |
|---|---|
| 2021-11-05 | U.S. Patent No. 12,031,784 Priority Date |
| 2022-09-08 | U.S. Patent No. 12,038,247 Priority Date |
| 2024-07-09 | U.S. Patent No. 12,031,784 Issued |
| 2024-07-16 | U.S. Patent No. 12,038,247 Issued |
| 2025-08-09 | Cease and Desist Letter Delivered to Defendants |
| 2025-12-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,038,247 - "Firearm Trigger Mechanism"
The Invention Explained
- Problem Addressed: The patent background notes a desire among some shooters to increase the rate of semi-automatic fire, which has led to techniques like "bump firing" ('247 Patent, col. 1:41-43). While forced reset triggers exist to achieve this mechanically, the patent states that "Further improvement in forced reset triggers is desired" ('247 Patent, col. 2:14-15). The implicit problem is the lack of a single, integrated mechanism that allows a user to easily select between a standard semi-automatic mode and a forced-reset mode.
- The Patented Solution: The invention is a trigger mechanism with a three-position safety selector that provides "safe, standard semi-automatic, and forced reset semi-automatic positions" (’247 Patent, Abstract). In the standard mode, a disconnector functions conventionally, requiring the user to release the trigger to reset the hammer (’247 Patent, col. 10:20-25). In the forced reset mode, a pivoting "cam" is engaged by the cycling bolt carrier, which in turn "forces the trigger member to the set position" while a feature on the safety selector prevents the disconnector from catching the hammer (’247 Patent, col. 9:28-59). This allows the user to fire again without manually releasing the trigger.
- Technical Importance: The invention provides a drop-in trigger module that gives the user the option of a conventional semi-automatic rate of fire or a mechanically assisted rapid rate of fire, selectable via the standard safety lever (Compl. ¶23).
Key Claims at a Glance
- The complaint asserts independent claim 15.
- Essential elements of Claim 15 include:
- A hammer, trigger member, and disconnector.
- A movable cam with a cam lobe.
- Operation in a "standard semi-automatic mode" where the disconnector catches the hammer, and the user must manually release the trigger to fire again.
- Operation in a "forced reset semi-automatic mode" where the cam is in a second position, the cam lobe forces the trigger to reset, and the disconnector hook is prevented from catching the hammer, allowing the user to pull the trigger again to fire.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger"
The Invention Explained
- Problem Addressed: The patent’s background section explains that forced reset triggers are often designed for a specific firearm platform, such as the AR15 (’784 Patent, col. 1:19-20). Due to dimensional differences in related platforms like the AR10, a trigger’s locking member that is long enough to be actuated by an AR10 bolt carrier would physically interfere with the cycling of an AR15 bolt carrier, rendering the device inoperable (’784 Patent, col. 1:39-44).
- The Patented Solution: The invention is a trigger locking device for a forced reset mechanism that includes a "locking member" with two key parts: a main "body portion" and an "upwardly extending deflectable portion" (’784 Patent, col. 2:58-64). This upward extension is what contacts the bolt carrier. It is designed to be rigid when pushed from the rear by the bolt carrier (to unlock the trigger), but it can pivot or "fold" rearward when contacted from the front by a lower part of the cycling bolt carrier (’784 Patent, col. 3:52-62; Fig. 7). This one-way hinging action allows the locking member to be tall enough for various platforms while avoiding interference during the firing cycle.
- Technical Importance: This design allows a single forced reset trigger mechanism to be compatible with multiple firearm platforms that have different physical dimensions and bolt carrier profiles.
Key Claims at a Glance
- The complaint asserts independent claim 1.
- Essential elements of Claim 1 include:
- A locking member for a forced reset trigger mechanism, movable between a first (locked) and second (unlocked) position.
- The locking member is configured to be actuated by contact with a bolt carrier surface.
- 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 and a deflected position.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are primarily the "Super Safety" and "ARC-Fire" trigger kits sold by Defendants (Compl. ¶25). The complaint also accuses various individual components sold for use with these kits, such as the "SS Cam + Lever" and "Precut Trigger for SS" (Compl. ¶28).
Functionality and Market Context
The complaint alleges that the accused "Super Safety" and "ARC-Fire" kits are sold as aftermarket components for AR-pattern firearms (Compl. ¶27). When installed as instructed, they allegedly function as forced reset trigger mechanisms (Compl. ¶25). The complaint includes a photograph from the Defendants' website showing the "ARC-FIRE TRIGGER - AMBI KIT" (Compl. p. 6, ¶26). Defendants are also alleged to sell components that adapt these kits for use in other firearm platforms, such as the MP5 (Compl. ¶30).
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... | The accused Super Safety kit is installed with a standard AR-pattern hammer that has a sear catch and a hook for a disconnector. | ¶44 | col. 7:45-53 |
| a trigger member having a sear... | The kit is installed with a trigger member that has a sear to engage the hammer's sear catch. | ¶44 | col. 7:50-56 |
| a disconnector having a hook for engaging said hammer... | The kit is used with a standard disconnector that has a hook for engaging the hammer. | ¶44 | col. 8:59-62 |
| a cam having a cam lobe and adapted to be movably mounted... | The Super Safety kit includes a cam component with a cam lobe that is movably mounted in the fire control pocket. | ¶44 | col. 8:5-9 |
| whereupon in a standard semi-automatic mode, said cam is in said first position, rearward movement of the bolt carrier causes... said disconnector hook [to catch] said hammer hook... a user must manually release said trigger member... to fire the firearm | In the standard mode, the accused cam is in a first position, allowing the disconnector to catch the hammer after a shot, requiring a manual trigger release before the next shot can be fired. | ¶44 | col. 10:20-34 |
| whereupon in a forced reset semi-automatic mode, said cam is in said second position, rearward movement of the bolt carrier causes... said disconnector hook [to be] prevented from catching said hammer hook... | In the forced reset mode, the cam moves to a second position, forcing the trigger to reset while preventing the disconnector from engaging the hammer, as illustrated in a diagram showing the hammer after rearward pivoting. | ¶44 | col. 9:28-59 |
- Identified Points of Contention:
- Scope Questions: The analysis may focus on whether the combination of the accused "Super Safety" cam and the firearm's safety selector function together to meet the limitations of a single "safety selector" as recited in the patent, which "prevents" the disconnector from catching the hammer hook in the forced reset mode.
- Technical Questions: A key question will be whether the accused products, when installed, operate in two distinct modes that map precisely onto the claim language. For example, does the accused cam remain in a "first position" throughout the "standard semi-automatic mode," and does it reliably prevent disconnector engagement in the "forced reset semi-automatic mode" as claimed?
’784 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a locking member that is movable between a first position in which it locks a trigger... and a second position where it does not restrict movement... | The accused Super Safety operates as a locking member, moving between a locked first position and an unlocked second position. | ¶70 | col. 1:53-58 |
| said locking member... including a generally upward extension portion configured to make actuating contact with a surface of a bolt carrier... | The Super Safety has an upward extending lever arm that makes contact with the surface of the bolt carrier to unlock the trigger. | ¶70 | col. 1:58-62 |
| the locking member having a body portion that is movably supported... | The Super Safety has a body portion that is movably supported by the firearm's lower receiver (frame). | ¶70 | col. 2:61-63 |
| and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position. | The Super Safety is alleged to have an upwardly extending lever arm (deflectable portion) that is separately movable from its body portion via a dovetail joint, as illustrated in a diagram comparing its extended and deflected states. | ¶70 | col. 2:63-65 |
- Identified Points of Contention:
- Scope Questions: A central dispute may be whether the accused product's design, which the complaint cites as using a "dovetail joint" (Compl. p. 39), meets the claim limitation of a "deflectable portion that is separately movable relative to the body portion." The interpretation of "separately movable" will be critical.
- Technical Questions: Evidence will be required to show that the alleged "lever arm" of the accused device actually moves independently of the "body portion" during the firing cycle in the manner required by the claim (i.e., deflecting to allow the bolt carrier to pass without causing the entire locking member to pivot).
V. Key Claim Terms for Construction
Patent: ’247 Patent
- The Term: "a safety selector"
- Context and Importance: Claim 15 requires the safety selector to perform a key function in the forced reset mode: "preventing the disconnector hook from catching the hammer hook." The accused products appear to be separate components installed alongside a standard safety selector. The case may turn on whether the accused "cam" is itself part of the "safety selector" or if the claim requires a single, integrated component to perform both the safety selection and disconnector-blocking functions.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not require the safety selector to be a single, monolithic piece. One could argue that any combination of components, including the selector lever and the accused cam it actuates, that collectively performs the claimed functions constitutes "a safety selector."
- Evidence for a Narrower Interpretation: The specification consistently depicts the safety selector (110) as a discrete component that has portions (116) that directly interact with and constrain the disconnector (60) ('247 Patent, Fig. 6A-6B, col. 8:55-61). This may support an interpretation that the "safety selector" itself must be the component that directly prevents the disconnector's movement.
Patent: ’784 Patent
- The Term: "separately movable"
- Context and Importance: This term is the core of the asserted independent claim and defines the novel feature of the locking device. Infringement hinges on whether the accused product's lever arm is "separately movable" from its body. Practitioners may focus on this term because it distinguishes the invention from a rigid, one-piece locking member.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The summary of the invention describes the upward extension portion as "separately movable relative to the body portion between an extended position and a deflected position" ('784 Patent, col. 1:63-65). This could be interpreted to cover any mechanism, including the alleged dovetail joint, that allows the extension to move without corresponding movement of the entire body.
- Evidence for a Narrower Interpretation: The detailed description and figures show a specific embodiment where the "foldable extension portion 22... pivots on... a transverse pivot pin 24 relative to the locking bar body 26" ('784 Patent, col. 3:40-43; Figs. 2-4). This could support a narrower construction requiring a distinct pivoting or hinging connection, rather than just limited play within a joint.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both contributory and induced infringement of the ’247 Patent. Inducement is based on Defendants allegedly providing instructions and videos for installation and use that guide customers to assemble an infringing device (Compl. ¶36). Contributory infringement is based on allegations that Defendants sell components that are especially made for an infringing use and are not staple articles of commerce (Compl. ¶33-34, ¶45).
- Willful Infringement: Willfulness is alleged for all infringement counts. The basis is Defendants' alleged continued infringement after receiving a cease and desist letter on August 9, 2025, which provided actual notice of the ’247 Patent and the infringement accusations (Compl. ¶18-19, ¶39, ¶66, ¶73).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural definition (’784 Patent): Does the accused products' "dovetail joint" design, which allegedly permits limited travel before engagement, meet the claim requirement for an upward extension that is "separately movable relative to the body portion," or does the claim require a more distinct, independent mechanism like a hinge?
- A key question will be one of operational scope (’247 Patent): Do the accused products, when installed and operated, satisfy all the functional limitations of both the "standard" and "forced reset" modes as recited in claim 15, particularly with respect to how the disconnector is controlled and how the trigger is reset in each distinct mode?
- A central question for damages will be one of willfulness: Given the complaint’s allegation that Defendants received and ignored a specific pre-suit notice of infringement, the determination of whether their subsequent conduct was willful will likely be a significant focus of the litigation.