DCT

2:26-cv-00033

ABC IP LLC v. Cope

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00033, E.D. Tex., 01/13/2026
  • Venue Allegations: Plaintiffs allege venue is proper because the Defendant, an individual, has committed acts of infringement in the district and maintains a regular and established place of business in Tyler, Texas.
  • Core Dispute: Plaintiffs allege that Defendant’s aftermarket firearm triggers and trigger kits, which enable a "forced reset" functionality, infringe six patents related to forced reset trigger mechanisms.
  • Technical Context: The technology concerns trigger mechanisms for semi-automatic firearms, specifically those designed to mechanically reset the trigger upon the cycling of the firearm's action, which can enable a more rapid rate of fire.
  • Key Procedural History: The complaint alleges that Plaintiffs sent a cease and desist letter to the Defendant on March 28, 2025, identifying five of the six patents-in-suit and accusing the "(3-Position) Super Safety" product of infringement. This notice serves as the primary basis for the willfulness allegations.

Case Timeline

Date Event
2017-09-29 Priority Date for ’223 Patent
2019-12-24 ’223 Patent Issued
2021-11-05 Priority Date for ’784 Patent
2022-01-10 Priority Date for ’003, ’336, and ’807 Patents
2022-09-08 Priority Date for ’247 Patent
2023-08-15 ’003 Patent Issued
2024-07-09 ’784 Patent Issued
2024-07-16 ’247 Patent Issued
2024-07-16 ’336 Patent Issued
2025-03-28 Cease and Desist Letter Sent to Defendant
2025-04-15 ’807 Patent Issued
2026-01-13 Complaint Filed

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

U.S. Patent No. 12,038,247 - *"Firearm Trigger Mechanism"*

The Invention Explained

  • Problem Addressed: Standard semi-automatic triggers limit the rate of fire because a user must consciously release the trigger to allow it to reset before the next shot can be fired (Compl. ¶¶20-21). Prior art solutions to increase firing rates were complex, required practice, or necessitated non-standard firearm components like a modified bolt carrier (’247 Patent, col. 1:44-51).
  • The Patented Solution: The invention introduces a selectable-mode trigger mechanism that uses a pivoting "cam" actuated by the firearm's bolt carrier as it cycles. In "forced reset" mode, the cam's movement forces the trigger member back to its reset position, allowing for a faster subsequent shot (’247 Patent, Abstract). In this mode, a safety selector also prevents the disconnector from catching the hammer, which is a necessary step for the forced reset cycle to function correctly (’247 Patent, col. 2:44-51).
  • Technical Importance: This approach provides a "drop-in" trigger assembly that can offer both standard and accelerated semi-automatic firing modes without requiring modification to a standard M16-pattern bolt carrier assembly (Compl. ¶23).

Key Claims at a Glance

  • The complaint asserts independent claim 15.
  • Claim 15 recites a firearm trigger mechanism comprising:
    • A hammer with a sear catch and a hook for a disconnector.
    • A trigger member with a sear.
    • A disconnector with a hook to engage the hammer.
    • A cam with a cam lobe, movable between a first and second position.
    • In the second ("forced reset") position, the cam lobe forces the trigger member towards its set position.
    • The claim further specifies the sequence of operations in both a "standard semi-automatic mode" (where the disconnector catches the hammer) and a "forced reset semi-automatic mode" (where the cam is in the second position and the disconnector hook is prevented from catching the hammer).

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

The Invention Explained

  • Problem Addressed: Prior forced reset trigger designs that use a rigid locking bar to prevent out-of-battery firing may not be compatible with certain firearm platforms (e.g., the AR-10 platform). Geometric differences in the bolt carrier mean a locking bar tall enough to be actuated by the rear of the bolt carrier would physically interfere with the front of the bolt carrier as it cycles to the rear (’784 Patent, col. 1:21-44).
  • The Patented Solution: The invention is an extended trigger member locking device featuring an upward extension that is "separately movable relative to the body portion" (’784 Patent, Abstract). This design, exemplified as a one-way hinge, allows the extension to be pushed by the bolt carrier to unlock the trigger when the action is in battery, but also allows it to fold or deflect out of the way to avoid interference as the front of the bolt carrier passes over it during rearward cycling (’784 Patent, col. 2:50-60; Fig. 7).
  • Technical Importance: This innovation allows the forced reset trigger concept to be adapted for use in firearms with varied bolt carrier geometries where a monolithic locking bar would be inoperable (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts independent claim 1.
  • Claim 1 recites an extended trigger member locking device for a forced reset trigger, comprising:
    • A locking member movable between a first (locked) position and a second (unlocked) position.
    • The locking member is movably supported by a frame.
    • It includes a "generally upward extension portion" that makes "actuating contact" with the bolt carrier.
    • This contact causes the locking member to move from the locked to the unlocked position.
    • (Note: The full claim as issued also recites that the upward extension is a "deflectable portion that is separately movable relative to the body portion," a limitation not included in the complaint's recitation of the claim language.)

U.S. Patent No. 10,514,223 - *"Firearm Trigger Mechanism"*

  • Technology Synopsis: This patent describes a forced reset trigger mechanism where the cycling of the hammer, as it is pushed back by the bolt carrier, makes contact with the trigger member and forces it into the reset position. A separate locking bar prevents the trigger from being pulled again until the bolt carrier has returned to a substantially in-battery position (Compl. ¶25; ’223 Patent, Abstract).
  • Asserted Claims: Claim 4 (Compl. ¶72).
  • Accused Features: The complaint alleges the Second, Third, and Fourth Infringing Devices, which are 2- and 3-position forced reset triggers and a kit, infringe this patent (Compl. ¶¶73-76).

U.S. Patent No. 11,724,003 - *"Firearm Trigger Mechanism"*

  • Technology Synopsis: This patent describes a trigger mechanism with a three-position safety selector for "safe, standard semi-automatic, and forced reset semi-automatic positions." In the forced reset mode, the cycling of the bolt carrier forces the trigger to reset, and the safety selector prevents the disconnector from catching the hammer (’003 Patent, Abstract). This is described as operating similarly to the other asserted patents with selectable modes (Compl. ¶26).
  • Asserted Claims: Claim 4 (Compl. ¶88).
  • Accused Features: The complaint alleges the Third Infringing Device (3-Position WOT) and by extension the Second and Fourth Infringing Devices infringe this patent (Compl. ¶¶89, 94).

U.S. Patent No. 12,036,336 - *"Firearm Trigger Mechanism"*

  • Technology Synopsis: This patent also describes a trigger mechanism with a three-position safety selector for "safe, standard semi-automatic, and forced reset semi-automatic positions." When in the forced reset position, the safety selector is configured to cause the disconnector to be repositioned, preventing it from catching the hammer hook during the cycle (’336 Patent, Abstract). This is described as operating similarly to the other asserted patents with selectable modes (Compl. ¶26).
  • Asserted Claims: Claim 3 (Compl. ¶106).
  • Accused Features: The complaint alleges the Third Infringing Device (3-Position WOT) and by extension the Second and Fourth Infringing Devices infringe this patent (Compl. ¶¶107, 113).

U.S. Patent No. 12,274,807 - *"Firearm Trigger Mechanism"*

  • Technology Synopsis: This patent describes a trigger mechanism with a movable safety selector for "safe, standard semi-automatic, and forced reset semi-automatic positions." Similar to the '003 and '336 patents, it claims a system where, in the forced reset mode, the safety selector prevents the disconnector from catching the hammer hook as the action cycles and forces the trigger to reset (’807 Patent, Abstract). This is described as operating similarly to the other asserted patents with selectable modes (Compl. ¶26).
  • Asserted Claims: Claim 1 (Compl. ¶125).
  • Accused Features: The complaint alleges the Third Infringing Device (3-Position WOT) and by extension the Second and Fourth Infringing Devices infringe this patent (Compl. ¶¶126, 132).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies four products: the "(3-Position) 'Super Safety'" (First Infringing Device), the "Wide Open Trigger (WOT)" (Second), the "3-Position Wide Open Trigger" (Third), and a "(3-Position) Forced Reset Trigger Kit" (Fourth) (Compl. ¶¶28, 32, 36, 40). The detailed infringement allegations focus on the "Super Safety."

Functionality and Market Context

  • The "Super Safety" is alleged to be a kit of components that, when installed in an AR-pattern firearm, functions as a forced reset trigger mechanism (Compl. ¶¶29, 49). It allegedly uses a cam to force the reset of the trigger and lock it during the cycle of operation (Compl. ¶49). A photograph shows the "Super Safety" components, which include a cam, cam lever, and other parts intended to replace a standard safety selector (Compl. p. 7). The complaint alleges the device can be switched between safe, standard semi-automatic, and forced reset modes (Compl. ¶30).

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: When installed, the Super Safety is part of a forced reset trigger mechanism. ¶49 col. 6:33-34
a hammer having a sear catch and a hook for engaging a disconnector... The accused Super Safety is installed with a hammer (depicted in red) that has a sear catch and a hook for engaging a disconnector. ¶49 col. 4:11-26
a trigger member having a sear... The Super Safety is installed with a trigger member (depicted in brown) that has a sear. A rendering illustrates the trigger member and its sear (Compl. p. 14). ¶49 col. 3:51-65
wherein said sear and sear catch are in engagement in said set positions...and are out of engagement in said released positions... The sear of the trigger member and sear catch of the hammer are shown to be in engagement in the set position and out of engagement in the released position. ¶49 col. 4:27-30
said disconnector having a hook for engaging said hammer... The disconnector (depicted in orange) has a hook for engaging the hammer. A rendering depicts the hook engaged with the hammer (Compl. p. 15). ¶49 col. 5:1-12
and a cam having a cam lobe... The Super Safety has a cam with a cam lobe and lever. ¶49 col. 5:13-20
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 cam is movable between positions. In the second position (forced reset mode), the cam lobe allegedly forces the trigger member toward the set position. ¶49 col. 5:21-25
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 the 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. ¶49 col. 6:15-23

Identified Points of Contention

  • Functional Questions: A central question may be whether the accused "Super Safety" cam performs the specific dual functions required by claim 15. The claim requires that in the forced reset mode, the cam both (1) forces the trigger to reset and (2) ensures the disconnector hook is "prevented from catching said hammer hook." The complaint alleges this occurs (Compl. ¶49, p. 19), but the precise mechanism and evidence for how the accused product achieves this prevention will likely be a point of dispute.

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
In a forced reset trigger mechanism, an extended trigger member locking device, comprising: The Super Safety is alleged to be part of a forced reset trigger mechanism and functions as an extended trigger member locking device. ¶61 col. 5:11-13
a locking member that is movable between a first position in which it locks a trigger against pulling movement The Super Safety operates as a locking member and has a first position in which it locks the trigger member against pulling movement. ¶61 col. 5:14-16
and a second position where it does not restrict movement of the trigger member, The Super Safety is movable to a second position where it does not restrict movement of the trigger member. A rendering illustrates this unlocked second position (Compl. p. 25). ¶61 col. 5:17-19
the locking member configured to be movably supported by a frame The Super Safety is movably supported by the firearm's lower receiver, which functions as the frame. ¶61 col. 5:20-21
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, The Super Safety has an upward extending portion (lever arm) that makes actuating contact with a surface of the bolt carrier. ¶61 col. 5:22-24
such actuating contact causing the locking member to move from the first position to the second position, The actuating contact causes the locking member to move from the locked to the unlocked position. ¶61 col. 5:25-27

Identified Points of Contention

  • Scope Questions: Claim 1 of the ’784 Patent, as granted, further requires the locking member to have "a body portion... and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position." This limitation, which defines the core inventive concept of adapting the device for different firearm geometries, is absent from the complaint's claim chart. A key issue will be one of claim scope and evidentiary proof: does the accused "Super Safety" possess this separately movable or deflectable structure, and what evidence does the complaint provide to support this element, which it omits from its own chart?

V. Key Claim Terms for Construction

  • The Term: "separately movable relative to the body portion" (’784 Patent, Claim 1)

    • Context and Importance: This term is critical because it captures the patent's solution to the bolt carrier interference problem. Its construction will determine whether a single, rigid component could infringe, or if the claim requires a multi-piece or hinged structure. Practitioners may focus on this term because the complaint's infringement theory for the '784 patent appears to omit this limitation entirely.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language uses the general term "separately movable," which might be argued to cover flexible or resilient materials in addition to distinct, hinged parts.
      • Evidence for a Narrower Interpretation: The specification's primary embodiment shows a distinct "foldable extension portion 22" that pivots on a "transverse pivot pin 24" relative to the "locking bar body 26" (’784 Patent, col. 3:41-47; Fig. 2). This specific, hinged embodiment could support a narrower construction limited to multi-piece, articulated structures.

  • The Term: "prevented from catching said hammer hook" (’247 Patent, Claim 15)

    • Context and Importance: This term is central to the operation of the "forced reset" mode. The infringement analysis will depend on whether the accused device achieves this "prevention" in the same way as contemplated by the patent. Practitioners may focus on this term to determine if any interaction that merely makes it less likely for the disconnector to catch the hammer meets the claim's requirement of being "prevented."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not specify the mechanism of prevention in the claim itself, which could allow for various mechanical blocking or interference methods to fall within its scope.
      • Evidence for a Narrower Interpretation: The specification describes a specific mechanism where a safety selector in the forced reset position "prevents" the disconnector from pivoting with the trigger member, thereby disabling its ability to catch the hammer (’247 Patent, col. 5:48-61). This could be argued to limit the claim to mechanisms where the safety selector is the agent of prevention.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement through "encouraging, advertising, promoting, and instructing others" on how to use the accused products, particularly at trade shows (Compl. ¶¶50, 62, 77). Contributory infringement is alleged on the basis that the accused components are "specially designed and adapted" for infringement and are "not suitable for substantial noninfringing use" (Compl. ¶¶52, 63, 79).
  • Willful Infringement: Willfulness is alleged based on Defendant's continued infringement after receiving a cease and desist letter on March 28, 2025, which allegedly provided actual notice of the asserted patents and infringement allegations (Compl. ¶¶19, 53, 64).

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

  • A core issue will be one of structural and functional correspondence: Does the accused "Super Safety" locking device incorporate the "separately movable" extension recited in the ’784 patent, which was invented to solve a specific geometric interference problem, particularly given that Plaintiffs' own complaint chart omits this central claim limitation?
  • A key evidentiary question will be one of operative mechanism: What is the precise mechanism by which the accused device, when in its forced reset mode, "prevents" the disconnector from catching the hammer as required by the ’247 patent, and does this mechanism align with the scope of the claim as construed by the court?
  • A broader case theme will likely involve the cumulative scope of the patent family: With six asserted patents covering single-mode, selectable-mode, cam-driven, and adapted locking bar variations of the forced reset concept, a central question will be how the specific features of the accused devices map onto the distinct claim sets of each patent.