DCT

1:22-cv-00280

Rare Breed TRIGGERS LLC v. Strbac

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-00280, N.D. Ohio, 03/07/2022
  • Venue Allegations: Venue is alleged to be proper as Defendants reside in and/or have a regular and established place of business within the Northern District of Ohio.
  • Core Dispute: Plaintiffs allege that Defendants’ “FRT-15-3MD” line of forced reset triggers infringes a patent related to trigger mechanisms for semiautomatic firearms.
  • Technical Context: The technology concerns "forced reset triggers," which use the energy from a firearm's reciprocating bolt carrier to mechanically reset the trigger, enabling a significantly faster rate of fire than standard semiautomatic triggers.
  • Key Procedural History: The complaint alleges that Plaintiffs’ counsel sent a cease-and-desist letter to Defendants on January 17, 2022, expressly accusing them of infringing the patent-in-suit, which may be used to support allegations of willful infringement.

Case Timeline

Date Event
2017-09-29 '223 Patent Priority Date
2019-12-24 '223 Patent Issue Date
2020-12-XX Plaintiffs' Rare Breed FRT-15™ trigger introduced to market
2022-01-17 Plaintiffs' counsel sends cease and desist letter to Defendant
2022-03-07 Complaint Filed

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

U.S. Patent No. 10,514,223 - “Firearm Trigger Mechanism”

The Invention Explained

  • Problem Addressed: The patent's background section describes a desire among firearm users to increase the rate of fire of semiautomatic firearms. It notes that in a standard trigger mechanism, the user cannot manually release and reset the trigger quickly enough to match the speed of the firearm's mechanical cycle, which requires a "disconnector" component to prevent malfunctions like "hammer follow" (where the hammer follows the bolt carrier forward without firing a round) ('223 Patent, col. 1:26-40). Existing solutions to increase firing rates are described as being complex, requiring significant user practice, or not being easily retrofitted ("drop-in") into popular firearm platforms ('223 Patent, col. 1:41-col. 2:29).
  • The Patented Solution: The invention is a semiautomatic trigger mechanism where the hammer, as it is pushed back by the reciprocating bolt carrier during the firing cycle, makes physical contact with the trigger member and forcibly pushes it back to the "set" position. A separate "locking bar" then mechanically blocks the trigger, preventing it from being pulled again until the bolt carrier has fully returned to its "in-battery" (ready-to-fire) position. This interaction, depicted in the patent's Figure 5, eliminates the need for a traditional disconnector and ensures the firearm can only be fired when the action is safely closed, while allowing for a very rapid firing sequence ('223 Patent, Abstract; col. 2:38-50).
  • Technical Importance: The invention provides a self-contained "drop-in" module that can be installed in standard AR-pattern firearms to significantly increase their potential rate of fire without modifying other key components like the bolt carrier ('223 Patent, col. 2:30-38).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 4, an independent claim (Compl. ¶62).
  • The essential elements of independent Claim 4 are:
    • A housing with openings for hammer and trigger assembly pins.
    • A hammer with a sear notch, mounted in the housing to pivot.
    • A trigger member with a sear, mounted in the housing to pivot, having a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier, with the contact forcing the trigger member to the set position.
    • A locking bar, pivotally mounted and spring-biased toward a first position where it mechanically blocks the trigger, and movable to a second position (when contacted by the in-battery bolt carrier) where the trigger can be moved.

III. The Accused Instrumentality

Product Identification

  • Defendants' "FRT-15-3MD" forced reset trigger models and a conversion kit called “The Ultimate Upgrade for the Rare Breed Trigger” (Compl. ¶48, ¶51).

Functionality and Market Context

  • The complaint alleges the accused FRT-15-3MD is a forced reset trigger that uses a hammer to forcibly reset the trigger and a locking bar to prevent the trigger from being pulled until the bolt carrier disengages the bar (Compl. ¶54). The complaint notes that the accused products also include a "disconnector mode," allowing the user to switch between a standard semiautomatic function and the forced reset function (Compl. ¶49). The "Ultimate Upgrade" product is alleged to be a kit of components that, when assembled with a customer's existing trigger housing, creates an infringing three-mode trigger assembly (Compl. ¶51-52). The accused products are alleged to be sold in direct competition with Plaintiffs' patented FRT-15™ trigger (Compl. ¶20, ¶70). A photograph provided in the complaint shows the internal components of the accused device, including the trigger, hammer, and locking bar (Compl. ¶50).

IV. Analysis of Infringement Allegations

Claim Chart Summary

  • The complaint provides a detailed, illustrated chart alleging infringement of Claim 4 of the '223 Patent. The core allegations are summarized below.

U.S. Patent No. 10,514,223 Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins; The accused products include a housing with aligned openings for hammer and trigger pins. ¶64 (p. 17-18) col. 4:35-50
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions; The accused products include a hammer with a sear notch that pivots on a transverse axis. ¶64 (p. 18-19) col. 4:24-29
a trigger member having a sear and mounted in the housing to pivot ... the trigger member having a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position; The accused products' trigger member has a surface that is contacted by the hammer during the firing cycle, forcing the trigger to reset. An image in the complaint specifically labels this "Surface contacted by hammer" on the accused device (Compl. ¶64, p. 19). ¶64 (p. 19-20) col. 5:33-39
a locking bar pivotally mounted in the housing and spring biased toward a first position in which the locking bar mechanically blocks the trigger member ... and movable ... to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved ... The accused products include a pivoting, spring-biased locking bar that blocks the trigger until it is moved by the bolt carrier returning to its in-battery position. The complaint includes a diagram showing the accused locking bar in its "FIRST POSITION" (blocking) and "SECOND POSITION" (unblocking) (Compl. ¶64, p. 21). ¶64 (p. 20-21) col. 5:61-col. 6:11

Identified Points of Contention

  • Scope Questions: The complaint alleges that the accused products' inclusion of an additional "disconnector mode" does not avoid infringement because Claim 4 uses the open-ended transitional phrase "comprising" (Compl. ¶49, ¶63). A potential point of contention may be whether this additional functionality alters the operation of the claimed elements in a way that takes the device outside the scope of the claim.
  • Technical Questions: What evidence does the complaint provide that the interaction between the hammer, trigger, and locking bar in the accused products is functionally identical to that required by the claim? The complaint's use of detailed, annotated photographs of the accused device's components (Compl. ¶64, pp. 17-21) provides facial support for its allegations, suggesting that a defense would need to demonstrate a subtle but material difference in mechanical operation.

V. Key Claim Terms for Construction

  • The Term: "a locking bar ... that mechanically blocks the trigger member"

  • Context and Importance: This term is central to the invention's safety feature, which prevents the trigger from being pulled before the bolt carrier is in battery. The manner and efficacy of this "blocking" function will be critical. Practitioners may focus on this term because any ambiguity in what constitutes a "mechanical block" could be exploited to argue non-infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language itself is functional, suggesting that any component that performs the function of mechanically blocking the trigger could satisfy the limitation, regardless of its specific shape or pivot point.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the lower end of the locking bar (62) moves into a position that physically obstructs the pivotal movement of the trigger member (26) ('223 Patent, col. 5:40-45; Fig. 5). A party might argue the term should be limited to this specific type of physical obstruction.

  • The Term: "contact causing the trigger member to be forced to the set position"

  • Context and Importance: This phrase defines the core "forced reset" action. The dispute will center on the nature of this "contact" and whether the force is transmitted in the way envisioned by the patent.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim requires only that "contact" between the hammer and trigger "causes" the trigger to be forced to reset. This could arguably cover a range of interactions where the hammer's motion impels the trigger's motion.
    • Evidence for a Narrower Interpretation: The detailed description explains this as "mechanical interference or contact between a rear surface 74 of the hammer 18 ... and a contact surface 30 of the trigger member 26" ('223 Patent, col. 5:33-37). A defendant could argue that the claim should be construed to require this specific surface-to-surface interaction.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants' "Ultimate Upgrade" kit is a material part of the patented invention and is not a staple article of commerce suitable for substantial non-infringing use, supporting a claim for contributory infringement (Compl. ¶53, ¶67). It further alleges that by providing the kit to be assembled by customers "as instructed," Defendants induce infringement (Compl. ¶52, ¶66).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants' continued infringing activity after receiving a cease and desist letter on January 17, 2022, that provided actual notice of the '223 Patent and the infringement allegations (Compl. ¶21, ¶60, ¶71).

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

  • A core issue will be one of functional equivalence: Do the internal components of the accused "FRT-15-3MD" trigger operate and interact in the precise mechanical sequence—particularly the hammer-to-trigger forced reset and the locking bar's blocking and release—as mandated by the specific limitations of Claim 4?
  • A key legal question will be one of indirect infringement: Does the sale of the "Ultimate Upgrade" kit, which contains components designed to be assembled with a third-party housing to create the allegedly infringing final product, constitute contributory infringement or inducement?
  • A central evidentiary question will concern willfulness: Does the evidence show that Defendants' conduct, particularly after receiving the January 17, 2022, cease-and-desist letter, was sufficiently egregious to warrant a finding of willful infringement and potential enhancement of damages?