ABC IP LLC v. Pistolcap Ltd Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: PistolCap Limited Company, d/b/a, Frisco Guns (Texas) and Mordekhai Harroch (an individual)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 2:26-cv-00053, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants have committed acts of infringement in the district and maintain a regular and established place of business there.
• Core Dispute: Plaintiff alleges that Defendant’s "Atrius Forced Reset Selector" infringes two patents related to selectable-mode firearm trigger mechanisms that mechanically force the trigger to reset after firing.
• Technical Context: The technology concerns trigger assemblies for semi-automatic firearms, particularly "forced reset triggers" which use the energy from the firearm's cycling action to reset the trigger, enabling a higher rate of fire than conventional mechanisms.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the asserted patents.

Case Timeline

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 provide "further improvement in forced reset triggers" for semi-automatic firearms (ʼ247 Patent, col. 2:15-16). Standard mechanisms require a user to manually release the trigger to reset the sear, which limits the rate of fire, and prior art forced reset mechanisms lacked certain advantageous features (ʼ247 Patent, col. 1:17-49).
• The Patented Solution: The patent describes a "drop-in" trigger module featuring a three-position safety selector for "safe, standard semi-automatic, and forced reset semi-automatic positions" (ʼ247 Patent, Abstract). The mechanism uses a pivoting cam that is actuated by the rearward movement of the bolt carrier. In "forced reset" mode, the cam forces the trigger member back to its set position, while the safety selector simultaneously prevents the disconnector from catching the hammer. In "standard" mode, the cam and selector allow the disconnector to function normally, requiring a manual trigger release to fire subsequent shots (ʼ247 Patent, Abstract; col. 3:55-4:10).
• Technical Importance: The invention provides a single, self-contained trigger assembly that allows a user to select between a conventional semi-automatic firing mode and an accelerated forced-reset mode, enhancing versatility for standard AR-pattern firearms (Compl. ¶19).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶27).
• Essential elements of Claim 15 include:
  • A firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a cam.
  • The cam is movable between a first position (for standard mode) and a second position (for forced reset mode) where a cam lobe forces the trigger member to its set position.
  • In standard mode, rearward movement of the bolt carrier causes the disconnector hook to catch the hammer hook, requiring a manual trigger release by the user to fire again.
  • In forced reset mode, rearward movement of the bolt carrier causes the disconnector hook to be prevented from catching the hammer hook, allowing the user to fire again without manually releasing the trigger.
• The complaint reserves the right to assert additional claims (Compl. ¶27).

U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger" (Issued July 9, 2024)

The Invention Explained

• Problem Addressed: The patent describes a geometric incompatibility when adapting forced reset triggers designed for one firearm platform (e.g., AR15) to another (e.g., AR10). The different dimensions and bolt carrier profile of an AR10 mean that a trigger-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 rearward, rendering the mechanism inoperable (ʼ784 Patent, col. 1:20-44).
• The Patented Solution: The invention is a trigger locking member with a "one-way hinge feature" (ʼ784 Patent, col. 1:66-67). It consists of a main body and an "upwardly extending deflectable portion" that is "separately movable" from the body (ʼ784 Patent, col. 2:63-67). This upward extension is rigid when pushed from the rear by the bolt carrier (which unlocks the trigger), but it is designed to fold or deflect out of the way when the front of the bolt carrier passes over it during rearward cycling, thus avoiding interference (ʼ784 Patent, col. 1:47-53; Fig. 7).
• Technical Importance: This design allows a forced reset trigger mechanism to function in firearm platforms with different internal geometries, overcoming the spatial constraints that made prior designs unworkable across different models (Compl. ¶20).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶41).
• Essential elements of Claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • A locking member movable between a first (locked) position and a second (unlocked) position.
  • The locking member has an upward extension to make "actuating contact" with the bolt carrier.
  • The locking member comprises two key parts: 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 and a deflected position.
• The complaint reserves the right to assert additional claims (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

The "Three-Position 'Atrius Forced Reset Selector'" (the "Infringing Device") (Compl. ¶22).

Functionality and Market Context

The complaint alleges the Infringing Device is a trigger mechanism that can be switched between "safe, standard semiautomatic with disconnector, and forced reset semiautomatic with cam modes" by rotating a safety selector (Compl. ¶25). It is marketed and sold through Defendant Frisco Guns' website (Compl. ¶23). A screenshot from the website shows the product advertised as a "3 POSITION FORCED RESET SELECTOR COMPATIBLE W/ MILSPEC AR-15" (Compl. p. 6).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint's infringement theory relies heavily on plaintiff-generated renderings. A central question will be whether these renderings accurately depict the internal operation of the accused device.
  • Technical Questions: A key factual dispute may arise over the final limitation: What is the precise mechanism by which the accused device "prevented" the disconnector from catching the hammer hook in forced reset mode? The evidence must show that the accused selector performs this specific function, as opposed to achieving a similar outcome through a different technical pathway.

’784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The infringement analysis will likely focus on the meaning of "separately movable relative to the body portion." The dispute may center on whether this language requires two distinct components joined by a physical hinge (as shown in the patent's embodiments) or if it can also read on a single, integrated component with a flexible or "living hinge" section.
  • Technical Questions: What is the actual construction of the accused device's upward-extending arm? Is it a distinct component that pivots relative to the main body, or is it a single piece of material designed to flex? The answer to this factual question will be critical for determining literal infringement.

V. Key Claim Terms for Construction

For the ’247 Patent (Claim 15)

• The Term: "prevented from catching said hammer hook"
• Context and Importance: This phrase defines the key functional difference between the claimed "standard" and "forced reset" modes. Infringement requires proving that the accused safety selector performs this specific blocking action. Practitioners may focus on this term because it distinguishes the invention from triggers that are merely reset by the hammer without an explicit disconnector-blocking feature tied to the selector.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is functional and does not specify how the prevention occurs. The specification explains that a "narrow semi-circular portion 116" of the selector "prevents the disconnector 60 from pivoting" (ʼ247 Patent, col. 8:62-65), which could support an interpretation covering any selector shape that achieves this result.
  • Evidence for a Narrower Interpretation: The figures show a direct physical interaction where a part of the selector body (116) obstructs the disconnector tail (66) (ʼ247 Patent, Fig. 6A). A party might argue the term should be limited to this specific type of direct mechanical obstruction.

For the ’784 Patent (Claim 1)

• The Term: "separately movable relative to the body portion"
• Context and Importance: This term is central to the patent's solution for adapting the trigger to different firearm platforms. The infringement analysis for the ʼ784 patent hinges on whether the accused device's construction meets this structural and functional limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "separately movable" is not explicitly defined. It could be argued to encompass any design where the extension portion can move (e.g., deflect, bend, or pivot) without causing corresponding movement of the entire locking member body, regardless of whether it is a two-piece assembly.
  • Evidence for a Narrower Interpretation: The patent's embodiments explicitly show a two-piece construction with a "foldable extension portion 22 that pivots on...a transverse pivot pin 24 relative to the locking bar body 26" (ʼ784 Patent, col. 3:41-44; Fig. 2). This could support an argument that "separately movable" requires two distinct, mechanically joined parts, not an integrated flexible member.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for each patent. Inducement is based on allegations that Defendants encourage and instruct customers to use the Infringing Device in an infringing manner, citing promotional materials on their website (Compl. ¶¶ 30, 44, pp. 18, 28). Contributory infringement is based on allegations that the device's components are specially designed for infringing use and have no substantial non-infringing purpose (Compl. ¶¶ 32, 46).
• Willful Infringement: Willfulness is alleged for both patents, based on the assertion that Defendants knew or should have known their actions constituted infringement and proceeded despite an objectively high likelihood of infringement (Compl. ¶¶ 33, 47). The complaint does not plead specific facts indicating pre-suit knowledge.

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

• A core issue will be one of structural interpretation: can the claim term "separately movable relative to the body portion" in the ʼ784 patent be construed to cover the specific design of the accused product's upward-extending arm? The case may depend on whether the claim requires a two-piece, hinged assembly as depicted in the patent's figures, or if it is broad enough to read on other one-way flexible designs.
• A key evidentiary question will be one of functional proof: does the accused product's safety selector, when in the forced-reset position, perform the specific function of "preventing" the disconnector from catching the hammer, as required by Claim 15 of the ʼ247 patent? The resolution of this issue will likely depend on expert analysis of the accused device's precise mechanical operation through its full cycle.