DCT
1:25-cv-00389
ABC IP LLC v. Hoffman
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
- Defendant: Timothy Hoffman (individual) and Hoffman Tactical LLC (Tennessee)
- Plaintiff’s Counsel: Whitaker Chalk Swindle & Schwartz PLLC
- Case Identification: 1:25-cv-00389, E.D. Tenn., 12/23/2025
- Venue Allegations: Venue is based on Defendants residing in the district and/or having a regular and established place of business within the district.
- Core Dispute: Plaintiffs allege that Defendants’ "Super Safety" device, which is distributed as a 3D-printable design, infringes three patents related to forced reset firearm trigger mechanisms.
- Technical Context: The technology involves "forced reset triggers" for semi-automatic firearms, which use the energy from the firearm's cycling action to mechanically reset the trigger, enabling a faster rate of fire than conventional mechanisms.
- Key Procedural History: The complaint details a significant history between the parties, including a prior dispute over a related (but not asserted) patent that culminated in a February 2022 settlement agreement. Plaintiffs allege this history, along with Defendants' public statements, establishes knowledge of the patent portfolio and willful intent to infringe. One of the patents-in-suit, U.S. Patent No. 7,398,723, expired in September 2024; thus, infringement allegations for this patent are limited to the period before its expiration.
Case Timeline
| Date | Event |
|---|---|
| 2003-04-25 | ’723 Patent Priority Date |
| 2008-07-15 | ’723 Patent Issue Date |
| 2021-11-05 | ’784 Patent Priority Date |
| 2022-02-09 | Plaintiffs sent cease-and-desist letter regarding different patent |
| 2022-02-24 | Parties entered settlement agreement over different patent |
| 2022-03-06 | Defendants posted YouTube video re: prior dispute |
| 2022-09-08 | ’247 Patent Priority Date |
| 2023-07-21 | Accused "Super Safety" design files first introduced for download |
| 2024-03-14 | ’247 Patent application published |
| 2024-07-09 | ’784 Patent Issue Date |
| 2024-07-16 | ’247 Patent Issue Date |
| 2024-09-22 | ’723 Patent Expired |
| 2025-03-03 | Defendants posted download file for ".308 super safety" lever |
| 2025-08-15 | Defendants posted YouTube video discussing infringement claims |
| 2025-12-23 | Complaint Filing Date |
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 seeks to improve upon prior art forced reset triggers, noting a desire for a mechanism that can be easily retrofitted into popular firearm platforms like the AR-pattern rifle without requiring modification to other standard components, such as the bolt carrier assembly (U.S. 12,038,247 B2, col. 1:14-15, 2:17-25).
- The Patented Solution: The invention is a self-contained "drop-in" trigger module that provides the user with three modes of operation, selectable via a safety selector: safe, standard semi-automatic, and forced reset semi-automatic (U.S. 12,038,247 B2, Abstract). In the forced reset mode, the rearward movement of the firearm's bolt carrier causes a cam to pivot, which in turn forces the trigger member back to its set position; a key aspect is that the safety selector interacts with the disconnector to prevent it from catching the hammer, thereby enabling rapid subsequent firing once the bolt returns to battery (U.S. 12,038,247 B2, col. 8:55-65).
- Technical Importance: The technology provides a selectable forced reset capability in a modular unit, allowing users to install an advanced fire control group into a standard firearm without specialized gunsmithing or permanent alterations to the host weapon (U.S. 12,038,247 B2, col. 2:21-25).
Key Claims at a Glance
The complaint asserts at least independent Claim 15 (Compl. ¶62). Its essential elements include:
- A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
- The cam is movable between a first position (for standard semi-automatic mode) and a second position (for forced reset mode).
- In the standard semi-automatic mode, the cam is in the first position, and after firing, the disconnector hook catches the hammer hook, requiring the user to manually release the trigger to reset the mechanism.
- In the forced reset semi-automatic mode, the cam is in the second position, where its lobe forces the trigger member toward its set position, and the disconnector hook is "prevented from catching said hammer hook."
U.S. Patent No. 12,031,784 - “Adapted Forced Reset Trigger,” issued July 9, 2024
The Invention Explained
- Problem Addressed: The patent background explains that forced reset trigger mechanisms are often designed for specific firearm geometries (like the AR15). If such a mechanism is installed in a dimensionally different platform (like the AR10), the locking member that interacts with the bolt carrier may be either too short to be actuated or, if lengthened, long enough to interfere with the bolt carrier as it cycles rearward ('784 Patent, col. 1:20-44).
- The Patented Solution: The invention is an extended trigger locking member featuring an "upwardly extending deflectable portion" ('784 Patent, Abstract). This upper portion is rigid enough to be actuated by the bolt carrier when it moves into battery (to unlock the trigger), but it is also designed to "deflect or fold" out of the way to allow the bolt carrier to pass over it during its rearward cycle without interference ('784 Patent, col. 4:26-39; Fig. 7).
- Technical Importance: This innovation allows a forced reset trigger design to be adapted for use across multiple firearm platforms with varying internal dimensions, enhancing its versatility and applicability ('784 Patent, col. 1:5-12).
Key Claims at a Glance
The complaint asserts at least independent Claim 1 (Compl. ¶72). Its essential elements include:
- An extended trigger member locking device for a forced reset trigger mechanism.
- A locking member movable between a first (locked) and second (unlocked) position, actuated by contact with a bolt carrier.
- The locking member has a movably supported "body portion."
- The locking member also has an "upwardly extending deflectable portion that is separately movable relative to the body portion" between an extended and a deflected position.
U.S. Patent No. 7,398,723 - “Trigger Forward Displacement System and Method,” issued July 15, 2008
- Patent Identification: U.S. Patent No. 7,398,723 B1, "Trigger Forward Displacement System and Method," issued July 15, 2008.
- Technology Synopsis: This patent discloses a method for accelerating the firing cycle of a semi-automatic firearm (Compl. ¶34). It describes a mechanism where the firearm's reciprocating bolt carrier actuates a cam, which in a single rotational motion, "simultaneously push[es] the trigger forward into a ready to fire position and hold[s] the trigger forward" until the firearm's action has closed and is ready to fire again (Compl. ¶40; ’723 Patent, col. 12:20-30).
- Asserted Claims: At least Claim 1 (Compl. ¶84).
- Accused Features: The complaint alleges that users of the "Super Safety" device practice the method of Claim 1 by depressing the trigger, which activates the reciprocating bolt carrier, which in turn causes the "Super Safety" cam to rotate and force the trigger forward into its reset position (Compl. p. 40-43). The complaint includes a YouTube screenshot showing the Defendant premiering a video titled "Introducing the Super Safety" on July 21, 2023, which it alleges is evidence of infringement prior to the patent's expiration (Compl. p. 38).
III. The Accused Instrumentality
Product Identification
The accused products are the "Super Safety" and ".308 super safety" devices, which are primarily distributed as downloadable digital files (e.g., 3D print files, STEP files, SolidWorks files) that enable third parties to manufacture the physical trigger components (Compl. ¶¶ 20, 23, 47). These are referred to collectively as the "Infringing Devices" and "Infringing Designs" (Compl. ¶27).
Functionality and Market Context
The "Super Safety" is described on Defendants' website as a "3D printable active trigger system for the AR-15" which "actively resets, allowing faster more efficient follow up shots" (Compl. p. 13). The complaint alleges it functions as a selectable trigger, allowing the user to switch between a standard semi-automatic mode and a forced reset mode (Compl. ¶50). A screenshot from the Odysee platform shows a download file for a lever, which Plaintiffs allege is part of the infringing design (Compl. p. 4). Plaintiffs allege that Defendants offer the designs for free download with the express intent to "overwhelm the market," dilute Plaintiffs' patent rights, and make enforcement "difficult, if not impossible" (Compl. ¶31).
IV. Analysis of Infringement Allegations
U.S. 12,038,247 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A firearm trigger mechanism comprising: a hammer... a trigger member... a disconnector... and a cam having a cam lobe... | When installed, the Super Safety is part of a forced reset trigger mechanism and functions as a cam that, in at least one mode, forces the reset of the trigger. A diagram shows the Super Safety (yellow) installed with a hammer (red), disconnector (orange), and trigger (brown) in a receiver pocket. | ¶64, p. 19 | col. 2:31-35 |
| 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 Super Safety cam is movable between positions. In the second position (forced reset mode), the cam lobe forces the trigger member toward the set position. | ¶64, p. 23 | col. 8:5-10 |
| whereupon in a standard semi-automatic mode, ... said disconnector hook catches said hammer hook, ... a user must manually release said trigger member to free said hammer from said disconnector... | In standard semi-automatic mode, the cam is in its first position, and the disconnector hook catches the hammer hook, requiring the user to manually release the trigger to reset the system. | ¶64, p. 24-25 | col. 8A:55-63 |
| whereupon in a forced reset semi-automatic mode, ... said disconnector hook is prevented from catching said hammer hook, | When in the forced reset mode, the cam is in the second position and forces the trigger toward the set position, while the disconnector hook is prevented from catching the hammer hook. | ¶64, p. 26 | col. 8B:46-54 |
- Identified Points of Contention:
- Scope Questions: The analysis may focus on the interpretation of "prevented from catching said hammer hook." The court will need to determine if the specific mechanism by which the accused device allegedly disables the disconnector—an interaction with the safety selector—falls within the scope of this functional language as understood from the patent's specification and prosecution history.
- Technical Questions: A key factual question will be whether the accused "Super Safety," when set to its "forced reset" mode, actually performs the function of preventing the disconnector from engaging the hammer during the weapon's cycle, as alleged by Plaintiffs and required by the claim.
U.S. 12,031,784 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| In a forced rest trigger mechanism, an extended trigger member locking device, comprising: a locking member that is movable between a first position... and a second position... | The Super Safety operates as a locking member that is part of a forced reset trigger mechanism and is movable between a first "Locked" position and a second "Unlocked" position. | ¶74, p. 30-31 | col. 5:14-23 |
| including a generally upward extension portion configured to make actuating contact with a surface of a bolt carrier, | The Super Safety has an upward extending lever arm configured to make contact with the surface of the bolt carrier, causing the locking member to move from the first to the second position. | ¶74, p. 32 | col. 5:26-31 |
| the locking member having a body portion that is movably supported and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position. | The Super Safety has a body portion supported by the receiver and an upwardly extending deflectable lever arm. A "dovetail connection" is alleged to allow separate movement of the lever arm relative to the body portion between an extended and deflected position. | ¶74, p. 33 | col. 5:32-38 |
- Identified Points of Contention:
- Scope Questions: A central dispute is likely to be the meaning of "separately movable relative to the body portion." The question will be whether the alleged movement within the accused device's "dovetail connection" constitutes the separate, deflectable motion described by the patent, which illustrates distinct pivot and hinge structures.
- Technical Questions: Evidence will be needed to establish how much, and in what manner, the accused device's lever arm actually moves relative to its body. The analysis will question whether this movement is sufficient to perform the claimed function of avoiding interference with a cycling bolt carrier in target firearms like the AR-10.
V. Key Claim Terms for Construction
For the '247 Patent
- The Term: "prevented from catching said hammer hook" (Claim 15)
- Context and Importance: This limitation defines the key functional difference between the claimed "standard" and "forced reset" modes. The infringement case for this patent hinges on whether the accused device achieves this "prevention" in its forced reset mode. Practitioners may focus on this term because the specific mechanical interaction that causes the prevention is the core of the forced-reset functionality.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional and does not specify how the prevention must occur. This may support an interpretation that covers any mechanism within the device that achieves this outcome.
- 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 with the trigger member 38 thus preventing the disconnector hook 64 from catching the hammer hook 53" ('247 Patent, col. 8:55-61). This language may support an argument that the claim scope is limited to a direct mechanical blocking of the disconnector by the safety selector.
For the '784 Patent
- The Term: "separately movable relative to the body portion" (Claim 1)
- Context and Importance: This phrase captures the novel aspect of the '784 patent: the two-part construction of the locking member that solves the bolt carrier interference problem. The dispute will center on whether the accused device's dovetail joint provides for movement that is truly "separate" as contemplated by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the invention provides a "deflectable extension" that "deflects or folds" ('784 Patent, col. 2:46-48). This language could support a broader construction that includes any form of relative movement that achieves the goal of avoiding interference, not just a classic hinge.
- Evidence for a Narrower Interpretation: The specification and figures consistently show embodiments with a distinct "hinging structure" or "pivot pin" (e.g., pin 24 in Fig. 2) that creates a clear axis of rotation ('784 Patent, col. 3:26-32, 4:40-45). This could support a narrower construction limited to a true pivoting or hinging action, as opposed to any incidental play in a different type of joint.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that by providing downloadable 3D printer files, STEP files, and instructions on how to manufacture, assemble, and use the Super Safety, Defendants actively induce infringement by end-users (Compl. ¶¶ 49, 66, 78).
- Willful Infringement: The complaint makes extensive allegations to support willfulness. It cites a prior 2022 settlement agreement over a related patent as evidence of pre-suit knowledge of Plaintiffs' portfolio (Compl. ¶24). It further alleges that Defendant Hoffman made public statements about his intent to "overwhelm the market" with free designs to make patent enforcement "difficult, if not impossible," and that he acknowledged infringement in a private phone call (Compl. ¶¶ 28, 31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "separately movable," which is described in the '784 patent's specification with reference to pivots and hinges, be construed to cover the relative motion allegedly allowed by the accused device's dovetail joint?
- A key evidentiary question will be one of functional operation: Does the accused "Super Safety" device, when in its forced reset mode, employ a mechanism that "prevents" the disconnector from engaging the hammer as required by Claim 15 of the '247 patent, or is there a fundamental mismatch in its technical operation?
- Beyond the technical merits, a central focus of the litigation will likely be on willfulness: Given the detailed history of prior dealings and the alleged public statements of intent, the court will have to determine whether any infringement was the result of a deliberate and egregious plan to disregard known patent rights, which could expose Defendants to enhanced damages.