DCT

2:26-cv-00030

ABC IP LLC v. Mars Trigger LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00030, E.D. Tex., 01/12/2026
  • Venue Allegations: Venue is asserted based on Defendants residing, committing acts of infringement, and having a regular and established place of business within the Eastern District of Texas.
  • Core Dispute: Plaintiffs allege that Defendants’ "Super Safety" forced reset trigger mechanisms infringe patents related to selectable multi-mode trigger operation and adaptable locking mechanisms for semi-automatic firearms.
  • Technical Context: The technology concerns aftermarket trigger mechanisms for AR-pattern firearms, designed to mechanically force the reset of the trigger using the energy from the cycling bolt carrier, thereby enabling a higher rate of semi-automatic fire.
  • Key Procedural History: The complaint alleges that in March 2025, Defendant Peter Brennen participated in a conference call with the President of Plaintiff Rare Breed, during which it was explained that sales of the accused device constituted infringement of the '247 Patent and '784 Patent. This allegation of pre-suit notice is central to the claim of willful infringement.

Case Timeline

Date Event
2021-11-05 U.S. Patent No. 12,031,784 Priority Date
2022-09-08 U.S. Patent No. 12,038,247 Priority Date
2023-07-19 Date of "Super Safety Guide" for Accused Product
2024-07-09 U.S. Patent No. 12,031,784 Issues
2024-07-16 U.S. Patent No. 12,038,247 Issues
2025-03-XX Alleged conference call providing Defendants notice of infringement
2026-01-12 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 “’247 Patent”)

The Invention Explained

  • Problem Addressed: The patent seeks to provide "further improvement in forced reset triggers" beyond existing designs, which may require modified bolt carriers or lack selectable modes of operation (Compl. ¶¶ 17-19; ’247 Patent, col. 2:14-15).
  • The Patented Solution: The invention is a trigger mechanism, usable in standard AR-pattern firearms, that provides three distinct, selectable modes: safe, standard semi-automatic, and forced reset semi-automatic. The mechanism uses a pivoting cam that is actuated by the bolt carrier's movement to force the trigger to reset. In the forced reset mode, a "three position" safety selector physically prevents the firearm's disconnector from catching the hammer, which allows the user to fire again immediately upon the action cycling without having to manually release and reset the trigger (Compl. ¶ 20; ’247 Patent, Abstract, col. 2:25-67).
  • Technical Importance: This design allows a user to select between a conventional semi-automatic firing mode and a rapid-fire forced-reset mode using a single integrated control (the safety selector) without modifying the firearm's bolt carrier assembly (Compl. ¶ 20).

Key Claims at a Glance

  • The complaint asserts independent Claim 15 (Compl. ¶ 35).
  • 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 the hammer.
    • A movable cam with a cam lobe.
    • In a "standard semi-automatic mode," the cam is in a first position, and the disconnector hook catches the hammer hook, requiring the user to manually release the trigger.
    • In a "forced reset semi-automatic mode," the cam is in a second position where the cam lobe forces the trigger member to its set position, and the disconnector hook is prevented from catching the hammer hook.
  • The complaint reserves the right to assert other claims (Compl. ¶ 35).

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

(Issued July 9, 2024; the “’784 Patent”)

The Invention Explained

  • Problem Addressed: Forced reset trigger mechanisms designed for one firearm platform (e.g., an AR15) may be inoperable in a dimensionally different platform (e.g., an AR10). A locking member long enough to be actuated by the AR10's bolt carrier might interfere with the carrier as it cycles rearward, rendering the device inoperable (’784 Patent, col. 1:21-44).
  • The Patented Solution: The patent describes a trigger locking device with a "deflectable" upward extension. This extension has a "one-way hinge feature" that makes it rigid when pushed from the rear by the bolt carrier returning to battery (allowing it to unlock the trigger), but allows it to fold or deflect away when pushed from the front by the bolt carrier cycling to the rear, thus avoiding interference (Compl. ¶ 21; ’784 Patent, Abstract, col. 2:46-52, col. 2:63-64).
  • Technical Importance: This innovation allows a single forced reset trigger design to be adapted for use in multiple firearm platforms with varying geometries between the trigger mechanism and the bolt carrier (Compl. ¶ 21).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (Compl. ¶ 47).
  • Essential elements of Claim 1 include:
    • An extended trigger member locking device for a forced reset trigger.
    • A locking member movable between a first (locked) position and a second (unlocked) position.
    • The locking member has an upward extension portion to make actuating 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.
  • The complaint reserves the right to assert other claims (Compl. ¶ 47).

III. The Accused Instrumentality

Product Identification

  • The "(3-Position) 'Super Safety'" (Compl. ¶ 23).

Functionality and Market Context

  • The accused device is a trigger mechanism for AR-pattern firearms marketed as a "MaRs 3 Position AR FRT Super Safety" (Compl., Ex. C, p. 7). The complaint alleges it is sold in several variations, including as a partial kit, a complete kit, and pre-installed in a firearm receiver (Compl. ¶ 25). The device is alleged to provide three selectable modes: safe, standard semi-automatic, and forced reset semi-automatic (Compl. ¶ 27). Marketing materials cited in the complaint state it is "Expertly crafted for AR platforms" and its "Forced Reset Mechanism" allows for "rapid firing speeds" (Compl., Ex. C, p. 7). The complaint includes a photograph of the accused device's components from the Defendants' website (Compl., Ex. C, p. 7).

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 accused "Super Safety" is installed in a receiver with a hammer (Red) that has a sear catch and a hook for engaging a disconnector (Orange). A plaintiff-generated rendering depicts these components assembled in a receiver pocket (Compl. p. 11). ¶37 col. 7:48-53
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, The disconnector (Orange) is mounted in the fire control pocket to pivot and has a hook to engage the hammer (Red). ¶37 col. 8:60-62
and 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 accused "Super Safety" device (Yellow) is identified as the claimed cam. It is movable between two positions, and in the second ("forced reset") position, its lobe forces the trigger member (Brown) toward the set position. ¶37 col. 8:1-14
whereupon in a standard semi-automatic mode, ...said disconnector hook catches said hammer hook, In standard semi-automatic mode, rearward movement of the bolt carrier causes the disconnector hook (Orange) to catch the hammer hook (Red). ¶37 col. 8:54-66, col. 9:1-25
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, When in forced reset mode, the cam is in its second position, which forces the trigger to reset while also preventing the disconnector hook from catching the hammer hook. ¶37 col. 9:26-67, col. 10:1-8
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the accused "Super Safety" device, which the complaint alleges is a multi-component assembly, constitutes a "cam" with a "cam lobe" within the meaning of the claim. The defense may argue that the term "cam" implies a single, monolithic component as depicted in the patent's figures.
    • Technical Questions: The analysis will likely focus on the precise mechanism by which the accused device allegedly "prevented" the disconnector from catching the hammer in the forced reset mode. The complaint does not provide a detailed mechanical explanation of this prevention step beyond showing the components' relative positions in plaintiff-generated renderings (Compl. p. 18).
      ’784 Patent 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 in which it locks a trigger against pulling movement and a second position... The accused "Super Safety" is alleged to be a locking device for a forced reset trigger. It is shown in plaintiff-generated renderings moving between a "Locked First Position" and an "Unlocked Second Position" (Compl. p. 25). ¶49 col. 2:53-58
the locking member having a body portion that is movably supported The Super Safety has a body portion that is movably supported by the firearm's lower receiver. ¶49 col. 2:60-62
and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position. The device's upward-extending lever arm is alleged to be the "deflectable portion." A "dovetail connection" is alleged to allow this lever arm to move separately from the body portion between an extended state (red) and a deflected state (green), as depicted in a close-up rendering from the complaint (Compl. p. 28). ¶49 col. 2:61-64
such actuating contact causing the locking member to move from the first position to the second position Contact from the bolt carrier on the upward extending portion causes the entire locking member to move from its locked to its unlocked position. ¶49 col. 6:1-4
  • Identified Points of Contention:
    • Scope Questions: The dispute may center on the definition of "deflectable portion." The patent describes embodiments with a "one-way hinge feature" and pivot pins (’784 Patent, col. 2:63-64). The question will be whether the alleged "dovetail joint" in the accused device (Compl. p. 29) meets the claim requirement of a "deflectable portion" that is "separately movable," or if it operates as a fundamentally different two-piece mechanical linkage.
    • Technical Questions: Evidence will be needed to establish whether the alleged "separate movement" of the accused device's lever arm is analogous to the "folding" or "deflecting" action described in the patent specification. The complaint quotes a guide for the accused product which describes how the "dovetail joint does not immediately transfer torque," suggesting a range of independent motion (Compl. p. 29).

V. Key Claim Terms for Construction

For the ’247 Patent:

  • The Term: "cam" (Claim 15)
  • Context and Importance: This term identifies the core component that interacts with the bolt carrier to force the trigger reset. The infringement analysis for Claim 15 depends on the accused "Super Safety" falling within the scope of this term. Practitioners may focus on this term because the accused device is an assembly, and the defense may argue "cam" implies a single component.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "cam having a cam lobe" without further structural limitation, which could support a construction covering any component that pivots and uses a lobe to impart motion (’247 Patent, col. 10:35-43).
    • Evidence for a Narrower Interpretation: The specification consistently depicts the cam 72 as a single, unitary component with an integral lobe 78 (’247 Patent, Fig. 3, col. 8:1-4). This could support an interpretation that limits the term to a single-piece construction.

For the ’784 Patent:

  • The Term: "deflectable portion that is separately movable relative to the body portion" (Claim 1)
  • Context and Importance: This phrase captures the patent's asserted point of novelty. Whether the accused device's two-piece, dovetail-jointed lever arm meets this limitation will likely be the dispositive issue for infringement of the ’784 Patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The Summary of the Invention describes the invention broadly as providing a "deflectable extension of the locking member," which suggests the function (deflection) is more important than the specific structure (’784 Patent, col. 2:46-47).
    • Evidence for a Narrower Interpretation: The detailed description explains this concept in terms of a "one-way hinge feature" and illustrates it using pivot pins and springs (’784 Patent, col. 2:63-64, Figs. 2, 8). This may support a narrower construction requiring a hinged or spring-biased flexing action, rather than simply the mechanical play within a joint.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement based on Defendants' advertising, website content, and the provision of installation instruction videos that allegedly encourage and instruct customers on how to infringe (Compl. ¶¶ 38, 50). Contributory infringement is alleged based on the sale of "partial kit" versions of the device, which are asserted to be specially designed for infringement and not staple articles of commerce (Compl. ¶¶ 29, 40, 52). An installation video is referenced as evidence of inducement (Compl., Ex. D, p. 20).
  • Willful Infringement: Willfulness is alleged based on Defendants' purported knowledge of the patents. The complaint specifically alleges that in March 2025, Defendant Peter Brennen was on a conference call where he was informed that the sale of the accused device infringed the patents-in-suit. The complaint alleges that infringement continued despite this direct, pre-suit notice (Compl. ¶¶ 41, 53).

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

  • A core issue will be one of definitional scope: Can the term "cam" in the ’247 Patent, which is depicted in the specification as a single component, be construed to read on the multi-part "Super Safety" assembly accused of infringing?
  • A key technical question will be one of functional operation: Does the "dovetail joint" in the accused device enable its lever arm to function as a "deflectable portion that is separately movable" as required by the ’784 Patent, or is there a fundamental mismatch between the accused product's mechanical linkage and the patented one-way hinge concept?
  • A critical factual question for damages will be willfulness: Did the alleged March 2025 conference call occur as described, and did it provide knowledge and notice sufficient to support a finding of willful infringement for any subsequent sales?