ABC IP LLC v. 80mills LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: 80MILLS LLC, d/b/a Tactical Titan Supply (Wyoming) and Pearson Gardner (individual)
  • Plaintiff’s Counsel: Wood Herron & Evans LLP
• Case Identification: 1:25-cv-01262, N.D. Ohio, 02/03/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Ohio because the Defendants reside in and/or have a regular and established place of business within the district.
• Core Dispute: Plaintiffs allege that Defendants’ “Super Safety” firearm modification kits infringe two patents related to forced reset trigger mechanisms for semi-automatic firearms.
• Technical Context: The technology at issue involves aftermarket firearm triggers designed to mechanically reset the trigger using the force of the firearm's cycling action, enabling a faster rate of fire than is typical with standard semi-automatic triggers.
• Key Procedural History: The complaint notes that on March 31, 2025, counsel for plaintiff ABC IP, LLC sent a cease and desist letter to defendant Tactical Titan Supply, which identified the ’247 Patent and accused the “Super Safety” product of infringement. This notice is cited as a basis for the willfulness allegation.

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. 12,038,247, “Firearm Trigger Mechanism,” issued July 16, 2024 (the “’247 Patent”) Compl. ¶13

The Invention Explained

• Problem Addressed: The patent background describes a desire among shooters to increase the rate of semi-automatic fire Compl. ¶19 ’247 Patent, col. 1:43-45 Standard triggers require a user to consciously release the trigger to reset the mechanism, which limits firing speed Compl. ¶22 The patent seeks to improve upon prior art forced reset triggers ’247 Patent, col. 2:15-16
• The Patented Solution: The invention is a trigger mechanism, adaptable as a "drop-in" module, that offers three distinct, selectable modes: "safe," "standard semi-automatic," and "forced reset semi-automatic" ’247 Patent, abstract ’247 Patent, col. 2:25-30 In the forced reset mode, the cycling of the firearm’s bolt carrier interacts with a cam, which in turn mechanically forces the trigger back to its reset position, allowing for rapid subsequent shots without the user needing to manually release the trigger ’247 Patent, abstract Compl. ¶19
• Technical Importance: The claimed invention provides the functionality of both a standard and a forced reset trigger within a single, selectable fire control group, offering versatility to the user.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 15 Compl. ¶41
• Independent Claim 15 recites the essential elements of a firearm trigger mechanism comprising:
  • A hammer, a trigger member, a disconnector, and a cam.
  • A "standard semi-automatic" mode where the cam is in a first position, rearward bolt movement causes the disconnector to catch the hammer, and the user must manually release the trigger to fire again.
  • A "forced reset semi-automatic" mode where the cam is in a second position, the bolt's rearward movement causes the cam lobe to force the trigger to its set position, and the safety selector prevents the disconnector from catching the hammer, allowing the user to fire again without a manual trigger release.

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

• Patent Identification: U.S. Patent No. 12,031,784, “Adapted Forced Reset Trigger,” issued July 9, 2024 (the “’784 Patent”) Compl. ¶14

The Invention Explained

• Problem Addressed: The patent background explains that a forced reset trigger designed for one firearm platform (e.g., an AR-15) may not be operable in another platform with different dimensions (e.g., an AR-10) ’784 Patent, col. 1:20-32 Specifically, modifying a locking bar to be tall enough to be actuated by the larger firearm's bolt carrier could cause it to interfere with the carrier during its rearward cycle ’784 Patent, col. 1:37-44
• The Patented Solution: The invention is an extended trigger locking device featuring a "deflectable" or "folding" upward extension ’784 Patent, abstract Compl. ¶20 This extension is rigid in one direction to allow the returning bolt carrier to actuate it and unlock the trigger, but it is designed to fold or give way in the other direction to avoid interfering with the bolt carrier as it cycles rearward ’784 Patent, col. 2:1-11
• Technical Importance: This design allows a single forced reset trigger architecture to be adapted for use across multiple firearm platforms with varying internal geometries, enhancing its modularity and market applicability.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 and dependent Claim 4 Compl. ¶58 Compl. ¶62
• Independent Claim 1 recites the essential elements of an extended trigger member locking device, comprising:
  • A locking member movable between a locked and an unlocked position.
  • The locking member includes an upward extension portion to make contact with a bolt carrier.
  • The locking member is composed of a movably supported "body portion" and an "upwardly extending deflectable portion."
  • The "deflectable portion" is "separately movable relative to the body portion" between an extended and a deflected position.

III. The Accused Instrumentality

Product Identification

• The accused products are the "Super Safety" (3 Position) device, sold as the "Super Safety Cam Kit – CPM10V/A2," a "Super Safety Fire Control Group (FCG) Completion Kit," and related components like precut triggers Compl. ¶¶26, 29, 31

Functionality and Market Context

• Defendants are alleged to sell a kit of parts, including a "specially made cam and cam lever" and a specially cut trigger, which, when installed as directed, creates the allegedly infringing trigger mechanism Compl. ¶29 The complaint alleges these parts are not staple articles of commerce and are especially made for an infringing purpose Compl. ¶33 Defendants are also alleged to sell a "Completion Kit" containing the remaining standard components needed to assemble the full mechanism Compl. ¶31 The products are allegedly sold through the "Tactical Titan Supply" website and social media pages Compl. ¶28 The complaint includes a screenshot from the Defendants’ website showing the "Super Safety Kit Builder" offered for sale Compl. p. 7

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

The complaint provides a chart alleging that the "Super Safety" device, when assembled and used as intended, infringes Claim 15 of the ’247 Patent Compl. ¶42 This analysis relies on plaintiff-generated renderings depicting the accused device's operation Compl. p. 12

’784 Patent Infringement Allegations

The complaint provides a chart alleging that the "Super Safety" device infringes Claim 1 of the ’784 Patent Compl. ¶59 A plaintiff-generated rendering shows the accused device's purported locking and unlocking movements Compl. p. 26

• Identified Points of Contention:
  • Scope Questions: For the ’784 Patent, a central issue may be whether the accused device's "dovetail joint" Compl. p. 30 falls within the meaning of a "deflectable portion that is separately movable relative to the body portion" as claimed. The complaint's evidence shows the lever arm pivoting within a void in the joint before transferring torque, and the court will have to determine if this mechanism meets the claim limitation.
  • Technical Questions: For the ’247 Patent, the infringement case relies on allegations about how a kit of parts functions when assembled. A question for the court will be whether the evidence, including plaintiff's own renderings, accurately portrays the function of Defendants’ product and proves that it performs every step of the claimed dual-mode operation.

V. Key Claim Terms for Construction

• The Term: "upwardly extending deflectable portion that is separately movable relative to the body portion" ’784 Patent, Claim 1
• Context and Importance: This term is the core of the claimed invention in the ’784 Patent, distinguishing it from prior art that was not adaptable across different firearm platforms. The infringement analysis for the ’784 Patent hinges on whether the accused "Super Safety" device, with its alleged dovetail joint, has a structure that meets this definition. Practitioners may focus on this term because the accused device's "dovetail" mechanism Compl. p. 30 is not an explicitly disclosed embodiment in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification uses varied language, including "deflects or folds" ’784 Patent, col. 1:49, a "one-way hinge feature" ’784 Patent, col. 1:64, and "foldable extension portion" ’784 Patent, col. 3:45, suggesting the claim is not limited to a single specific mechanism. The patent's summary describes the invention as providing a "deflectable extension" without limiting its structure ’784 Patent, col. 1:46-47
  • Evidence for a Narrower Interpretation: The embodiments depicted in the figures all show clear pivoting actions, using either a separate pivot pin (FIG. 2) or a single co-axial pivot pin (FIG. 8) ’784 Patent, Figs. 2, 8 A party could argue the term should be limited to such hinged or pivoting structures, as opposed to the rotational play within a dovetail joint alleged in the complaint.

VI. Other Allegations

• Indirect Infringement: The complaint pleads both induced and contributory infringement (Compl. Count I). It alleges inducement by asserting that Defendants market a kit of parts and "instruct purchasers to assemble" them in an infringing manner Compl. ¶35 Compl. ¶44 It alleges contributory infringement by asserting the sold components are "especially made or especially adapted for use in an infringement" and are not "staple article[s] of commerce suitable for substantial noninfringing use" Compl. ¶33
• Willful Infringement: The complaint alleges willfulness based on Defendants' continued infringing activities after receiving a cease and desist letter on March 31, 2025, which provided actual notice of the ’247 Patent and the infringement accusation Compl. ¶18 Compl. ¶39

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

This case presents several core questions for the court's determination.

• A primary issue will be one of indirect infringement liability: since Defendants are alleged to sell kits rather than fully assembled infringing devices, a central question is whether Plaintiffs can prove Defendants knowingly induced or contributed to direct infringement by end-users, and whether the sold components constitute non-staple articles with no substantial non-infringing use.
• A second issue will be one of definitional scope: can the term "deflectable portion that is separately movable" in the ’784 patent, disclosed as a hinged or pivoting element, be construed to cover the accused product's "dovetail joint" mechanism, which is alleged to allow rotational play before engagement?
• A key evidentiary question will be one of functional operation: does the accused "Super Safety" kit, when assembled, actually perform all of the functions required by claim 15 of the ’247 patent, particularly the specific, multi-step interactions between the cam, disconnector, and bolt carrier in both "standard" and "forced reset" modes?