DCT

4:23-cv-00021

Rare Breed TRIGGERS LLC v. Crawford

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:23-cv-00021, N.D. Okla., 01/13/2023
  • Venue Allegations: Venue is alleged to be proper as all defendants reside in and/or have a regular and established place of business in the Northern District of Oklahoma.
  • Core Dispute: Plaintiffs allege that Defendants’ “PARA-15” trigger infringes a patent related to a forced-reset trigger mechanism for semi-automatic firearms.
  • Technical Context: The technology concerns firearm trigger mechanisms designed to increase the rate of semi-automatic fire by using the firearm's own action to mechanically reset the trigger.
  • Key Procedural History: The complaint alleges a complex history involving prior litigation (the “Graves Lawsuit”) against a different entity, 7050 Corp., for infringing the same patent. It is alleged that Defendant Crawford was an agent and owner of entities involved in the Graves Lawsuit, had direct knowledge of the patent and infringement allegations, and misappropriated the design for the accused product from 7050 Corp. after Plaintiffs asserted that the design was infringing.

Case Timeline

Date Event
2017-09-29 U.S. Patent No. 10,514,223 Priority Date
2019-12-24 U.S. Patent No. 10,514,223 Issue Date
2020-12-01 Plaintiff's FRT-15™ trigger first introduced to market (approx.)
2022-03-08 Plaintiffs file "Graves Lawsuit" for infringement of the '223 Patent
2022-08-16 Accused triggerempire.com domain created
2022-08-24 Defendant MDN allegedly paid online influencers (on or after)
2023-01-13 Complaint Filing Date

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

U.S. Patent No. 10,514,223 - "Firearm trigger mechanism," issued December 24, 2019

The Invention Explained

  • Problem Addressed: The patent seeks to increase the rate of fire for semi-automatic firearms beyond what is achievable with standard trigger mechanisms or techniques like "bump firing" (’223 Patent, col. 1:16-54). It notes that prior art solutions were often complex, expensive, required significant user practice, or were not "drop-in" replacements for popular firearm platforms like the AR-15, sometimes requiring modification of major components like the bolt carrier (’223 Patent, col. 2:1-28).
  • The Patented Solution: The invention is a trigger mechanism where the cycling of the firearm's action forcibly resets the trigger, preparing it for the next shot much faster than a user could do manually (’223 Patent, Abstract). As the bolt carrier moves rearward, it pushes the hammer back into a cocked position. This rearward movement of the hammer, in turn, makes contact with a surface on the trigger member, forcing the trigger itself to return to its forward, reset position (’223 Patent, col. 5:30-37). A separate "locking bar" then mechanically blocks the trigger from being pulled again until the bolt carrier has returned to its forward, "in-battery" position, which prevents the hammer from falling prematurely ("hammer follow") (’223 Patent, col. 5:38-46; FIG. 5).
  • Technical Importance: The invention provides a self-contained, "drop-in" module that can be installed in standard AR-pattern firearms without permanent modification, offering a mechanical method to achieve a rapid rate of fire (’223 Patent, col. 2:30-43).

Key Claims at a Glance

  • The complaint asserts independent claim 4. (Compl. ¶91).
  • Claim 4 Essential Elements:
    • A trigger mechanism for a specified firearm environment (a firearm with a receiver, pocket, pin openings, and a reciprocating bolt carrier).
    • A "housing" with openings for hammer and trigger pins.
    • A "hammer" with a sear notch, pivotally mounted in the housing.
    • A "trigger member" with a sear, also pivotally mounted, and having a surface positioned to be contacted by the hammer during cycling, which forces the trigger to its set position.
    • A "locking bar" pivotally mounted in the housing, spring-biased to a first position where it blocks the trigger member, and movable to a second position by the bolt carrier when in battery, which un-blocks the trigger member.
  • The complaint does not explicitly reserve the right to assert other claims, but the infringement count is based on "at least Claim 4." (Compl. ¶91).

III. The Accused Instrumentality

Product Identification

  • The "Para-15 Drop in Trigger" (the "Infringing Device") (Compl. ¶74).

Functionality and Market Context

  • The complaint alleges the PARA-15 is a "drop-in" replacement trigger assembly for AR-pattern firearms (Compl. ¶74). It is marketed and sold online through the website www.triggerempire.com (Compl. ¶46). The complaint alleges the PARA-15 is a forced reset trigger that uses hammer contact to reset the trigger, in combination with a locking bar, thereby embodying the technology of the ’223 Patent (Compl. ¶53). A screenshot of the triggerempire.com website shows the product marketed with the phrase "INSTANTLY DECREASE YOUR RESET TIME" (Compl. ¶46). The complaint further alleges that the Defendants are selling the PARA-15 in direct competition with Plaintiffs' own FRT-15™ and WOT triggers, which are covered by the ’223 Patent (Compl. ¶25-26, 96).

IV. Analysis of Infringement Allegations

'223 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint ¶ Patent Col.
For a firearm having a receiver with a fire control mechanism pocket, assembly pin openings in side walls of the pocket, and a bolt carrier that reciprocates and pivotally displaces a hammer when cycled, a trigger mechanism, comprising: The PARA-15 is a trigger mechanism for an AR-pattern firearm, which has these components. The complaint provides an annotated diagram showing the receiver, pocket, and assembly pin openings. ¶92, p. 22 col. 3:35-44
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins; The Infringing Device includes a housing with such openings. An annotated photograph shows the blue housing of the PARA-15 with labeled openings. ¶92, p. 23 col. 3:40-44
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions; The Infringing Device includes a hammer with a sear notch that pivots on an axis. Annotated photographs show the hammer in both "SET" and "RELEASED" positions. ¶92, p. 23-24 col. 4:11-26
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions, 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 Infringing Device includes a trigger member with a sear and a surface that is allegedly contacted by the hammer during cycling to force the trigger to reset. Annotated photos identify the trigger member, sear, and contact surface. ¶92, p. 24-25 col. 5:33-37
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 from moving to the released position, and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved by an external force to the released position. The Infringing Device includes a "fin-shaped locking bar" that allegedly performs this function. Annotated photos show the locking bar in its first (blocking) and second (unblocking) positions. ¶92, p. 26-27 col. 5:38-61

Identified Points of Contention

  • Scope Questions: The complaint anticipates a dispute over the structure of the "locking bar," noting that the accused device uses a "fin-shaped locking bar" (Compl. ¶54). A central question will be whether the scope of the term "locking bar" as claimed in the patent is broad enough to read on the defendant's allegedly different "fin-shaped" design.
  • Technical Questions: A key factual question will be whether the interaction between the hammer, trigger member, and locking bar in the accused PARA-15 device operates in the specific manner required by the claim. This includes whether the hammer's movement causes the trigger to be forced to the set position, and whether the locking bar's movement is controlled by the bolt carrier's "in-battery" position as claimed. An annotated photograph of the PARA-15's components shows the locking bar, spring, and pivot axis, which will be central to this analysis (Compl. ¶92, p. 26).

V. Key Claim Terms for Construction

  • The Term: "a locking bar"

  • Context and Importance: This term is critical because the complaint alleges the Defendants use a "fin-shaped locking bar," suggesting a potential design-around argument (Compl. ¶54). The case may turn on whether this "fin-shaped" structure falls within the scope of the claimed "locking bar." Practitioners may focus on this term because its construction will determine whether a seemingly different component is legally equivalent to the claimed element.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims require the bar to be "pivotally mounted" and to perform a specific function: blocking the trigger member in a first position and being moved to a second, non-blocking position when contacted by the in-battery bolt carrier (col. 6:5-14). An argument could be made that any structure performing this pivotal blocking/unblocking function, regardless of its specific shape, meets the claim limitation.
    • Evidence for a Narrower Interpretation: The specification and figures illustrate a specific embodiment of the locking bar (62) (’223 Patent, FIG. 1-5). An argument could be made that the term should be limited to structures that are structurally similar to the disclosed embodiment, potentially excluding a "fin-shaped" bar if it is sufficiently different.

  • The Term: "comprising"

  • Context and Importance: The complaint itself highlights this term, arguing that because claim 4 is a "comprising" claim, "the inclusion of additional structures or features not specified in a claim does not avoid infringement" (Compl. ¶94). This is a foundational principle of claim interpretation, and its application here will be key to rebutting any argument that the "fin-shaped" locking bar is an "additional feature" that changes the overall device.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: "Comprising" is a term of art in patent law that presumptively means "including, but not limited to." The Manual of Patent Examining Procedure (MPEP) and extensive case law support the view that this term creates an open-ended claim, allowing for the presence of additional, unrecited elements in an infringing device.
    • Evidence for a Narrower Interpretation: While difficult, a defendant could argue that the addition of the "fin-shaped" element fundamentally changes the way the device operates, such that it no longer meets other limitations of the claim, even under the open-ended "comprising" transition. This is not an argument against the meaning of "comprising" itself, but rather its effect in the context of the overall claim.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges that Defendants indirectly infringe by "promoting, providing, and causing to be used" the Infringing Device (Compl. ¶91). It also alleges that Defendants paid online influencers to "tout the Infringing Device and advertise for its sale online" (Compl. ¶52, 89), which could be evidence of inducement.

Willful Infringement

  • The complaint lays a detailed foundation for willfulness. It alleges that Defendant Crawford, through his involvement in a prior lawsuit (the "Graves Lawsuit"), had direct, pre-suit knowledge of the ’223 Patent and Plaintiffs' infringement contentions against a similar product (Compl. ¶27-31, 40). It further alleges that Plaintiffs' representatives explicitly told representatives of an entity associated with Crawford that a prototype of the accused design was infringing (Compl. ¶32, 34). Finally, it alleges Defendants used an anonymous website (triggerempire.com) to conceal their identities (Compl. ¶49, 82, 85).

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

  • A core issue will be one of claim construction and scope: can the term "locking bar", as defined by its function in the claims and illustrated in the patent's figures, be construed to cover the accused "fin-shaped locking bar," or does the different shape constitute a non-infringing design-around?
  • A central legal and factual question will be willfulness: given the extensive allegations of pre-suit knowledge stemming from prior litigation and direct communications, the key dispute will be whether Defendants' alleged conduct rose to the level of egregious infringement behavior warranting enhanced damages, should liability be established.
  • An underlying issue will be one of corporate and individual liability: the complaint names multiple individual and corporate defendants. A key question for the court will be to unravel the alleged relationships between these parties to determine who is responsible for the alleged manufacturing, marketing, and sales of the accused trigger.