DCT

5:25-cv-00695

ABC IP LLC v. Z3 Productions LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-00695, W.D. Okla., 06/23/2025
  • Venue Allegations: Venue is alleged to be proper as the Defendant is organized under the laws of Oklahoma and maintains a regular and established place of business within the district.
  • Core Dispute: Plaintiffs allege that Defendant’s "Super Safety" firearm accessory kit, when assembled, infringes a patent related to a trigger mechanism that allows a user to select between a standard semiautomatic mode and a forced-reset mode that increases the rate of of fire.
  • Technical Context: The technology operates in the field of firearm accessories, specifically aftermarket trigger assemblies for AR-15 pattern rifles, a market characterized by high consumer demand for performance-enhancing modifications.
  • Key Procedural History: The complaint notes that on April 1, 2025, Plaintiff ABC IP, LLC sent a cease and desist letter to Defendant, providing actual notice of the patent and the infringement allegations. This event forms the basis for the claim of willful infringement.

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 Issue Date
2025-04-01 Cease and Desist Letter Sent to Defendant
2025-06-23 Complaint Filed

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

U.S. Patent No. 12,038,247 - FIREARM TRIGGER MECHANISM

Issued: July 16, 2024

The Invention Explained

  • Problem Addressed: The patent describes a desire among some firearm users to increase the rate of fire of semiautomatic firearms beyond what is typically possible with a standard trigger, which requires a user to consciously release the trigger to reset the mechanism for the next shot (Compl. ¶15-16; ’247 Patent, col. 1:41-54).
  • The Patented Solution: The invention is a trigger mechanism, particularly for AR-pattern firearms, that provides a "three position" selector for safe, standard semi-automatic, and forced reset semi-automatic modes (’247 Patent, Abstract). The core of the solution is a pivoting cam that is actuated by the firearm's reciprocating bolt carrier. In the "forced reset" mode, the cam physically pushes the trigger member back to its reset position as the action cycles, enabling a faster subsequent shot. In "standard" mode, the mechanism functions conventionally, requiring the user to manually release the trigger to fire again (Compl. ¶18-19; ’247 Patent, col. 2:55-col. 3:10).
  • Technical Importance: This design offers a selectable, dual-mode functionality within a single "drop-in" module, allowing a user to switch between a conventional rate of fire and an accelerated rate without needing to install or remove different components (Compl. ¶14; ’247 Patent, col. 2:23-26).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 15 (Compl. ¶33).
  • The essential elements of independent Claim 15 are:
    • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a movable cam with a cam lobe.
    • The mechanism includes a "standard semi-automatic mode" where, after firing, the disconnector catches the hammer, and the user must manually release the trigger to reset the mechanism.
    • The mechanism also includes a "forced reset semi-automatic mode" where the cam is in a second position, and rearward movement of the bolt carrier causes the hammer to pivot such that the disconnector hook is "prevented from catching" the hammer hook, allowing the user to fire again without manually releasing the trigger.

III. The Accused Instrumentality

Product Identification

  • The accused product is the "Super Safety" (3 Position) kit (Compl. ¶20).

Functionality and Market Context

  • The "Super Safety" is sold as a kit of components including a "specially made cam and cam lever that replaces a standard AR-pattern safety selector" and a jig for modifying a standard trigger member (Compl. ¶22). The complaint alleges that when these parts are installed in an AR-pattern firearm with other standard components, the resulting assembly creates the patented invention (Compl. ¶22). The Defendant allegedly sells the kit and related components, such as an "M16 Super Safety Centering Block," through its website and social media pages (Compl. ¶21, ¶23). An image from the Defendant's website shows the main component of the kit, which resembles a firearm safety selector. (Compl. ¶34, p.6). The complaint alleges the assembled device allows a user to switch between safe, standard semi-automatic, and forced reset semi-automatic modes (Compl. ¶28).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
A firearm trigger mechanism comprising: 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... The Infringing Device is installed in a fire control mechanism pocket and is used with a standard hammer that has a sear catch and a hook for engaging a disconnector. A provided diagram shows the device situated in a firearm's lower receiver. (Compl. ¶34, p.11). ¶34 col. 13:41-48
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 includes a cam with a cam lobe that is movably mounted. In its second position, the cam lobe forces the trigger member towards its set position. The complaint includes a figure illustrating the cam and its lobe. (Compl. ¶34, p.14). ¶34 col. 13:57-col. 14:2
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...a user must manually release said trigger member...to fire the firearm, and In the standard mode, the cam is in a first position. The bolt carrier's movement causes the disconnector to catch the hammer hook, requiring the user to manually release the trigger. An annotated diagram shows this operational state. (Compl. ¶34, p.15). ¶34 col. 14:3-16
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 user can pull said trigger member to fire the firearm. In the forced reset mode, the cam is moved to a second position, and the disconnector hook is prevented from catching the hammer hook, allowing the user to pull the trigger again. A diagram illustrates this mode of operation. (Compl. ¶34, p.16). ¶34 col. 14:17-26

Identified Points of Contention

  • Scope Questions: The patent specification and figures appear to show the "cam" and the "safety selector" as two distinct components (e.g., ’247 Patent, Fig. 3, items 72 and 110). The accused device is allegedly a single component that replaces the standard safety selector and performs the function of the claimed cam (Compl. ¶22). This raises the question of whether the term "cam" in Claim 15 can be construed to read on a single, multi-function part that also serves as the safety selector, or if the claim requires two structurally separate parts.
  • Technical Questions: The infringement theory is based on contributory and induced infringement, as the Defendant sells a kit of parts rather than a fully assembled mechanism (Compl. ¶33). A key question for the court will be whether the components sold by the Defendant are, as alleged, "especially made or especially adapted for use in an infringement" and lack "substantial noninfringing use," which are statutory requirements for contributory infringement (Compl. ¶25, ¶35).

V. Key Claim Terms for Construction

The Term: "cam"

  • Context and Importance: This term is central to the invention's operation and the infringement dispute. The Defendant's product allegedly integrates the cam function into the safety selector component (Compl. ¶22). The construction of "cam" could determine whether a single, dual-function component falls within the claim scope. Practitioners may focus on this term because its interpretation—whether structural or purely functional—could be dispositive of infringement.
  • Intrinsic Evidence for a Broader Interpretation: Claim 15 recites a "cam" without requiring it to be structurally separate from a safety selector, focusing instead on its function of having a lobe and being movable between two positions to force the trigger to reset (’247 Patent, col. 13:57-col. 14:2). This could support an interpretation where any component performing these recited functions is a "cam," regardless of its other roles.
  • Intrinsic Evidence for a Narrower Interpretation: Other claims in the patent, such as independent claim 1, separately recite "a cam" and "a safety selector" (’247 Patent, col. 10:41-52). The patent's detailed description and figures also consistently depict the cam (72) and safety selector (110) as distinct parts (’247 Patent, Fig. 3). This may support an argument that one of ordinary skill in the art would understand the term "cam" in the context of the entire patent to mean a component that is structurally separate from the safety selector.

The Term: "disconnector hook is prevented from catching said hammer hook"

  • Context and Importance: This phrase defines the key functional difference of the "forced reset" mode. The mechanism by which this "prevention" occurs in the accused device will be compared to the mechanism disclosed in the patent.
  • Intrinsic Evidence for a Broader Interpretation: The claim language is purely functional; it describes the result ("is prevented") without specifying the mechanism. This could support a reading that covers any structure that achieves this outcome.
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific embodiment where a "narrow semi-circular portion 116" of the safety selector "prevents the disconnector 60 from pivoting," which in turn prevents the hook from catching (’247 Patent, col. 8:55-62). A party might argue that the claim should be limited to this disclosed mechanical blocking action, rather than covering all possible ways of preventing the disconnector from engaging.

VI. Other Allegations

Indirect Infringement

  • The complaint exclusively asserts counts of indirect infringement (Compl. ¶32-39). It alleges contributory infringement by stating Defendant sells components that are a material part of the invention, are especially adapted for an infringing use, and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶25, ¶35). It alleges induced infringement by claiming Defendant "instructs purchasers to assemble the Infringing Devices in a way that induces infringement" (Compl. ¶27).

Willful Infringement

  • The complaint alleges willfulness based on Defendant's "continued infringement after ABC's demand letter" dated April 1, 2025, which allegedly provided Defendant with actual notice of the patent and the infringing conduct (Compl. ¶13, ¶31).

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

  • A core issue will be one of claim scope and construction: can the term "cam" in Claim 15, which does not explicitly recite a separate safety selector, be interpreted to cover a single component that performs the functions of both the cam and the safety selector, or does the context of the full patent limit the term to a structurally distinct part?
  • A second central question will be one of indirect liability: will Plaintiffs be able to prove that the components in Defendant's "Super Safety" kit have no substantial non-infringing use, a critical element for their contributory infringement claim? The answer may depend on whether the components can be used in a manner that does not assemble into the combination described in the patent claims.
  • Finally, a key evidentiary question will be one of functional operation: does the accused device's mechanism for preventing the disconnector from engaging the hammer in its "forced reset" mode operate in a manner consistent with the patent's claims, or is there a fundamental difference in the way this function is achieved that may place it outside the bounds of the asserted claim?