ABC IP LLC v. Hush Distribution LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Hush Distribution, LLC (Texas)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 2:26-cv-00054, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the Defendant has committed acts of infringement and maintains a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendant’s "Super Safety" firearm trigger mechanism infringes two patents related to selectable, forced-reset trigger technologies that increase the semi-automatic rate of fire.
• Technical Context: The technology involves mechanical firearm components that use the energy from a fired round to reset the trigger, enabling a faster firing sequence than is possible with conventional semi-automatic triggers.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to 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 background describes a desire among some firearm users to increase the rate of semi-automatic fire, noting that conventional trigger mechanisms and techniques like "bump firing" have limitations (Compl. ¶15-16; ’247 Patent, col. 1:21-54). Standard triggers require a user to release the trigger to reset the mechanism, which limits firing speed (’247 Patent, col. 1:30-34).
• The Patented Solution: The invention is a trigger mechanism with a selectable "forced reset" mode. In this mode, the rearward movement of the firearm's bolt carrier after firing actuates a pivoting cam, which in turn physically forces the trigger member back to its reset position (’247 Patent, Abstract). This mechanical reset allows the user to fire the next round immediately, without needing to manually release the trigger, thereby bypassing the standard disconnector function and enabling a faster rate of fire (Compl. ¶18; ’247 Patent, col. 2:48-67). The mechanism can also be selected to operate in a standard semi-automatic mode.
• Technical Importance: This technology provides a "drop-in" module that can increase a firearm's rate of fire using a mechanical linkage to the existing action of the bolt carrier, without altering the fundamental semi-automatic operation of one round fired per trigger pull (Compl. ¶18; ’247 Patent, col. 2:22-26).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶25).
• Essential elements of claim 15 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 semi-automatic mode).
  • In the standard mode, the disconnector catches the hammer after firing, requiring a manual trigger release to reset.
  • In the forced reset mode, rearward movement of the bolt carrier causes the cam to force the trigger member to its set position, while preventing the disconnector from catching the hammer.
• The complaint does not explicitly reserve the right to assert dependent claims but references infringement of "one or more claims" (Compl. ¶25).

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 designed for one firearm platform (e.g., an AR15) may be inoperable in another platform (e.g., an AR10) due to different dimensions. Specifically, an extended locking member tall enough to be actuated by an AR10-pattern bolt carrier would interfere with the carrier as it cycles to the rear (’784 Patent, col. 1:21-44).
• The Patented Solution: The invention is a trigger locking device with a "deflectable" or "separately movable" upward extension. This extension is configured to be rigid when pushed from the rear by the bolt carrier moving into battery (which unlocks the trigger), but it pivots or folds backward to allow the lower surface of the bolt carrier to pass over it during rearward cycling without interference (’784 Patent, Abstract; col. 2:51-65). This is described as a "one-way hinge feature" in an embodiment (’784 Patent, col. 2:65-67; Fig. 7).
• Technical Importance: This design allows a forced reset trigger concept to be adapted for use in multiple firearm platforms with varying internal geometries, overcoming a key limitation of prior designs (Compl. ¶19; ’784 Patent, col. 1:45-49).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶39).
• Essential elements of claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • The device has a locking member movable between a first (locked) and second (unlocked) position.
  • The locking member has a "body portion" and an "upwardly extending deflectable portion."
  • The deflectable portion is "separately movable relative to the body portion" between an extended and a deflected position.
• The complaint references infringement of "one or more claims" (Compl. ¶39).

III. The Accused Instrumentality

• Product Identification: The accused product is the "(3-Position) 'Super Safety'" (Compl. ¶21).
• Functionality and Market Context:
  • The complaint alleges the Super Safety is a firearm trigger mechanism designed to be installed in AR-15 pattern firearms (Compl. ¶41, quoting Ex. C at 1).
  • It is alleged to operate in three modes selected by the user: safe, standard semi-automatic, and forced reset semi-automatic (Compl. ¶22).
  • In the forced reset mode, the device allegedly "functions as a cam that... both forces the reset of the trigger and locks the trigger during the cycle of operation" (Compl. ¶27). The complaint includes a plaintiff-generated rendering that identifies the accused device's hammer, disconnector, and the "Super Safety" component, which is alleged to function as the claimed cam. (Compl. ¶27, p. 7).
  • The complaint does not provide specific details on the product's market positioning beyond alleging that Defendant is making, using, and selling it through physical storefronts (Compl. ¶23).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint labels the entire "Super Safety" device as the "cam." A potential point of contention may be whether this single component performs all the functions of both the claimed "cam" and the claimed "safety selector," which the patent describes as distinct interacting parts (’247 Patent, Abstract). The analysis may question whether a single integrated component can meet limitations describing two separate but interacting components.
  • Technical Questions: A key technical question is how the accused device "prevents" the disconnector from catching the hammer in the forced reset mode. The complaint shows a plaintiff-generated rendering of the cam in its second position during the cycle (Compl. ¶27, p. 14). The case may turn on evidence of whether this interaction functions as claimed, or if the prevention of disconnector engagement occurs through a different mechanism.

’784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The central issue will be the construction of "separately movable relative to the body portion." The complaint's allegations and visuals, such as the rendering showing the upward extension making contact with the bolt carrier (Compl. ¶41, p. 22), appear to show the entire accused device pivoting as a single unit. A dispute may arise over whether this unitary movement satisfies the claim requirement for a "deflectable portion" that is "separately movable" from its "body portion."
  • Technical Questions: Does the accused device's "upward extending portion" merely pivot with the rest of the body, or does it have a separate degree of freedom (e.g., a hinge or flexible joint) that allows it to move independently, as described in the patent's embodiments? The complaint does not provide sufficient detail to analyze the internal structure of the accused device to resolve this question.

V. Key Claim Terms for Construction

For the ’247 Patent:

• The Term: "a safety selector"
• Context and Importance: Claim 15 recites both "a cam" and "a safety selector adapted to be mounted... to pivot between... standard semi-automatic, and forced reset semi-automatic positions." The definition of these as potentially separate elements is critical, as the accused Super Safety appears to be a single component alleged to perform functions of both. Practitioners may focus on whether the claim requires two distinct physical structures.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation (Integrated Function): The claims do not explicitly state the cam and selector cannot be a single, integrated part. A party could argue that as long as the functions of selecting a mode and forcing the trigger reset are performed, the limitations are met.
  • Evidence for a Narrower Interpretation (Separate Structures): The patent's detailed description and figures consistently depict the safety selector (110) and the cam (72) as physically separate components that interact (’247 Patent, Figs. 1-3, col. 8:43-45). The use of "a cam" and "a safety selector" in the claim suggests two distinct elements.

For the ’784 Patent:

• The Term: "separately movable relative to the body portion"
• Context and Importance: This phrase defines the core novelty of the ’784 patent—the non-interfering extension. The entire infringement case may hinge on whether the accused device's locking member contains a portion that is "separately movable."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses that the extension portion could be made from a "resilient material configured to deflectably bend" (’784 Patent, col. 4:48-51), which might support an argument that a separate pivot is not required and that flexing of a unitary component could qualify as "separately movable."
  • Evidence for a Narrower Interpretation: The abstract states the "upward extension portion... is separately movable relative to the body portion," and every embodiment described in detail shows a distinct physical pivot pin (24, 54) creating a hinge (’784 Patent, Figs. 2-4, 8-10; col. 4:39-44). This suggests the term requires a separate, articulated structure, not just a flexible part of a unitary body.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by "encouraging, advertising, promoting, and instructing others to use and/or how to use the Infringing Device" (Compl. ¶28, ¶42). Contributory infringement is alleged on the basis that components like the "cam and cam lever arm" are specially designed for infringing use and are not suitable for substantial non-infringing use (Compl. ¶30, ¶44).
• Willful Infringement: Willfulness is alleged based on "egregious infringement behavior with knowledge of the... Patent," with knowledge presumed to exist at least from the service of the complaint (Compl. ¶31, ¶45). No pre-suit knowledge is explicitly alleged.

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

• A central issue will be one of structural correspondence: Do the claims of the ’247 and ’784 patents, which describe multi-component systems (e.g., a "cam" and a "safety selector"; a "body portion" and a "separately movable" extension), read on the accused "Super Safety" device, which appears to be constructed as a single, unitary component?
• A key question of claim scope for the ’784 patent will be: Can the term "separately movable," which is illustrated in the patent's embodiments with a distinct physical hinge, be construed broadly enough to cover the alleged pivoting motion of the accused device, which appears to move as a single, rigid body?
• An ultimate evidentiary question will be one of technical function: Does the accused device actually prevent disconnector engagement in its forced reset mode using the mechanism required by the ’247 patent, and does its upward extension possess a separate degree of freedom as required by the ’784 patent, or do these functions occur in a manner materially different from that which is claimed?