DCT

1:25-cv-01262

ABC IP LLC v. 80mills LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01262, N.D. Ohio, 07/02/2025
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Ohio because the defendants reside and/or have a regular and established place of business in the district.
  • Core Dispute: Plaintiffs allege that Defendants’ “Super Safety” firearm trigger kits infringe a patent related to a selectable, mechanically forced-reset trigger mechanism for semi-automatic firearms.
  • Technical Context: The technology at issue involves trigger mechanisms for AR-15-pattern firearms designed to increase the rate of fire by using the firearm's cycling action to mechanically reset the trigger, bypassing the need for the user to manually release it between shots.
  • Key Procedural History: The complaint states that on March 31, 2025, counsel for Plaintiff ABC sent a cease and desist letter to Defendant Tactical Titan Supply, providing pre-suit notice of the patent and the infringement allegations.

Case Timeline

Date Event
2022-09-08 U.S. Patent No. 12,038,247 Priority Date
2024-07-16 U.S. Patent No. 12,038,247 Issued
2025-03-31 Plaintiffs’ counsel sent cease and desist letter to Defendants
2025-07-02 Complaint Filed

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”).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the desire among some firearm users to increase the rate of fire of semi-automatic firearms. It notes that a standard semi-automatic trigger includes a "disconnector" that holds the hammer after a shot is fired and requires the user to manually release the trigger to reset the mechanism before another shot can be fired. This manual reset action limits the maximum rate of fire. (Compl. ¶19; ’247 Patent, col. 1:26-34).
  • The Patented Solution: The invention is a trigger mechanism, particularly for AR-pattern firearms, that provides a three-position selector: "safe," "standard semi-automatic," and "forced reset semi-automatic" (’247 Patent, Abstract). In the "forced reset" mode, the rearward movement of the firearm’s bolt carrier during the firing cycle acts upon a pivoting cam. This cam, in turn, forces the trigger member back to its "set" or reset position, enabling the user to fire the next round immediately upon the action returning to battery, without needing to manually release the trigger. (’247 Patent, col. 3:1-10, Fig. 9C).
  • Technical Importance: The patented solution offers a "drop-in" trigger module that allows a user to select between a conventional semi-automatic firing mode and a mechanically accelerated firing mode within a single, integrated mechanism (’247 Patent, col. 2:23-26).

Key Claims at a Glance

  • The complaint asserts independent Claim 15. (Compl. ¶37).
  • Essential elements of Claim 15 include:
    • A hammer with a sear catch and a hook for a disconnector.
    • A trigger member with a sear.
    • A disconnector with a hook for engaging the hammer.
    • A movable cam with a cam lobe, capable of moving between a first position and a second position where it forces the trigger member towards its set position.
    • A "standard semi-automatic mode" where the cam is in a first position, and the disconnector catches the hammer, requiring a manual trigger release to reset.
    • A "forced reset semi-automatic mode" where the cam is in a second position, and the bolt carrier's movement causes rearward pivoting of the hammer such that the disconnector is prevented from catching the hammer hook.

III. The Accused Instrumentality

Product Identification

  • The accused products are identified as the “Super Safety” (3 Position) device and associated kits, including the “Super Safety Cam Kit – CPM10V/A2” and the “Super Safety Fire Control Group (FCG) Completion Kit” (the “Infringing Device”) (Compl. ¶¶23, 25, 27).

Functionality and Market Context

  • The complaint alleges Defendants sell a kit of specially made components, including a cam, cam lever, and a specially cut trigger, which are not staple articles of commerce (Compl. ¶¶25, 29). When these components are installed as directed into an AR-pattern firearm with other standard parts (which Defendants also allegedly sell in a "Completion Kit"), the resulting assembly is alleged to create the patented invention (Compl. ¶¶25, 27). The complaint alleges the assembled device provides selectable modes for safe, standard semi-automatic fire, and forced reset semi-automatic fire (Compl. ¶¶32-33). The devices are allegedly offered for sale on Defendants' website and social media pages (Compl. ¶24). An image from the accused seller's website shows various "Super Safety" components for sale, including a "Super Safety Kit Builder" and a "Curved Super Safety Cut Trigger" (Compl. p. 6).

IV. Analysis of Infringement Allegations

Claim Chart Summary

  • The complaint provides the following exemplary comparison of the accused product to Claim 15 of the ’247 Patent. (Compl. ¶38).

’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 to pivot on a transverse hammer pivot axis between set and released positions, said hammer adapted to be pivoted rearward by rearward movement of a bolt carrier, The Infringing Device is installed in a fire control mechanism pocket of a receiver along with a hammer that has a sear catch and a hook for engaging a disconnector. The complaint includes a diagram showing the hammer pivoting between set and released positions due to bolt carrier movement. ¶38 col. 7:49-53
a trigger member having a sear and adapted to be mounted in the fire control mechanism pocket to pivot on a transverse trigger member pivot axis between set and released positions, The Infringing Device is installed with a trigger member in the fire control mechanism pocket that pivots on a transverse trigger member pivot axis between set and released positions and has a sear. ¶38 col. 7:54-58
wherein said sear and sear catch are in engagement in said set positions of said hammer and trigger member and are out of engagement in said released positions of said hammer and trigger member, The sear and sear catch are in engagement when the hammer and trigger member are in their set positions. The complaint provides a diagram illustrating this engagement. ¶38 col. 7:58-62
said disconnector having a hook for engaging said hammer and adapted to be mounted in the fire control mechanism pocket to pivot on a transverse disconnector pivot axis, and The disconnector is adapted to be mounted in the fire control mechanism pocket to pivot on a transverse disconnector pivot axis. The disconnector has a hook for engaging the hammer. ¶38 col. 8:1-3
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 movably mounted in the fire control mechanism pocket. It is movable between a first and second position, where the second position forces the trigger member towards the set position, as illustrated in a complaint diagram. ¶38 col. 13:60-65
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, and thereafter the bolt carrier moves forward into battery, at which time a user must manually release said trigger member... In the standard semi-automatic mode, the cam is in a first position. Rearward movement of the bolt carrier causes rearward pivoting of the hammer such that the disconnector hook catches the hammer hook, requiring a manual release. ¶38 col. 14:4-21
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, and thereafter the bolt carrier moves forward into battery, at which time the user can pull said trigger member to fire the firearm. When in the forced reset semi-automatic mode, the cam is moved laterally to a second position. Rearward movement of the bolt carrier causes rearward pivoting of the hammer such that the disconnector hook does not catch the hammer hook, allowing the user to fire again. ¶38 col. 14:22-38

Identified Points of Contention

  • Scope Questions: The complaint alleges direct infringement by selling the components of the claimed combination (Compl. ¶¶46, 48). A key legal question may be whether selling a kit of unassembled parts constitutes making or selling the claimed "firearm trigger mechanism comprising..." under 35 U.S.C. § 271(a), or if infringement liability depends primarily on the indirect infringement theories also pleaded.
  • Technical Questions: The infringement theory relies on the accused components being combined with "a standard AR-pattern hammer and disconnector" (Compl. ¶25). The analysis may raise the question of what evidence demonstrates that the accused cam and trigger operate as claimed when combined with the full range of "standard" components available on the market, or if specific component pairings are required.

V. Key Claim Terms for Construction

The Term

  • "a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket" (from Claim 15)

Context and Importance

  • This term is central because Defendants are accused of selling a kit of parts, not a pre-assembled, mounted mechanism. Practitioners may focus on this term because the scope of "adapted to be movably mounted" could influence whether the sale of the unassembled cam component itself can be considered direct infringement, or if this language primarily describes the intended functional environment of the part for purposes of an indirect infringement analysis.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language "adapted to be" suggests the component is designed or configured for a specific purpose (mounting in the pocket), not necessarily that it must be sold in a pre-mounted state. The specification consistently describes the individual components and their intended placement within the firearm's receiver, which could support a construction focused on the component's design and intended use. (e.g., ’247 Patent, col. 8:5-7, "A cam 72 is movably mounted to the housing 12.").
  • Evidence for a Narrower Interpretation: The preamble of the claim is "A firearm trigger mechanism comprising:". A defendant might argue that to infringe, the accused device must be a "mechanism" at the time of sale, implying an assembled or substantially assembled state. The specification's primary embodiment shows the components assembled within a "drop-in" housing, which could be used to argue that the claim contemplates an integrated unit. (’247 Patent, Fig. 1; col. 2:23-26).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both contributory and induced infringement. The contributory infringement claim is based on allegations that Defendants sell components that are a material part of the invention, know they are "especially made or especially adapted for use in an infringement," and that the parts are not staple articles of commerce suitable for substantial noninfringing use (Compl. ¶¶28-29). The inducement claim is based on allegations that Defendants instruct purchasers on how to assemble the components into an infringing configuration (Compl. ¶31) and promote the components together as a unified product, such as the "Completion Kit" (Compl. ¶27).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants’ continued infringing conduct after receiving a cease and desist letter on March 31, 2025, which allegedly provided actual notice of the ’247 Patent and the infringement allegations (Compl. ¶¶16, 35, 43).

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

  • A core issue will be one of indirect infringement: As the accused products are sold as kits, the case will likely focus on whether Plaintiffs can prove Defendants possessed the requisite knowledge and specific intent to encourage infringement, and whether the specialized cam and trigger components have any substantial non-infringing uses.
  • A related question will be one of direct infringement liability: The court will need to determine whether selling a complete kit of parts, which when assembled by the end-user creates the claimed invention, constitutes "making" or "selling" the patented "firearm trigger mechanism" by the defendant under 35 U.S.C. § 271(a).
  • A central evidentiary question will be one of technical operation: Assuming the components are assembled as alleged, the case will turn on factual evidence demonstrating that the accused "Super Safety" system performs both the "standard semi-automatic mode" and the "forced reset semi-automatic mode" exactly as required by the final two functional limitations of Claim 15.