ABC IP LLC v. Prosource Firearms LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: ProSource Firearms, LLC (Texas)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Name: ABC IP, LLC v. ProSource Firearms, LLC
• Case Identification: 2:26-cv-00055, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the Defendant maintains a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiffs allege that Defendant’s aftermarket firearm trigger systems infringe two patents related to selectable, forced-reset trigger mechanisms designed to increase the rate of semi-automatic fire.
• Technical Context: The technology at issue involves mechanical trigger assemblies for AR-pattern firearms that use the energy from a cycling bolt carrier to mechanically reset the trigger, allowing for faster follow-up shots than traditional semi-automatic designs.
• Key Procedural History: The complaint states that Plaintiff ABC IP, LLC is the owner of the Asserted Patents by assignment and that Plaintiff Rare Breed Triggers, Inc. is the exclusive licensee.

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 firearm users to increase the rate of semi-automatic fire, noting the limitations of prior art methods and devices. (Compl. ¶¶15-17; ’247 Patent, col. 1:17-61). Standard trigger mechanisms require a user to consciously release the trigger to reset the sear, which limits the potential rate of fire. (Compl. ¶16).
• The Patented Solution: The invention is a trigger mechanism with a three-position safety selector: safe, standard semi-automatic, and forced reset semi-automatic. (Compl. ¶18; ’247 Patent, Abstract). In the forced reset mode, the rearward movement of the firearm’s bolt carrier pivots a cam, which in turn forces the trigger member back to its reset position. (Compl. ¶18; ’247 Patent, col. 2:55-65). Crucially, the safety selector in this mode also mechanically prevents the disconnector from engaging the hammer, allowing the user to fire again immediately upon the bolt carrier's return to battery without manually releasing the trigger. (’247 Patent, col. 4:1-11).
• Technical Importance: This design offers a selectable, integrated mechanical system to accelerate the firing sequence of a semi-automatic firearm, distinct from standard operation. (Compl. ¶18).

Key Claims at a Glance

• The complaint asserts independent claim 15. (Compl. ¶¶26, 28). The complaint also explicitly reserves the right to assert other claims. (Compl. ¶26).
• Essential elements of claim 15 include:
  • A standard fire control group comprising a hammer, a trigger member, and a disconnector.
  • A cam with a cam lobe, movable between a first position (where it does not force the trigger reset) and a second position (where it does).
  • A safety selector for pivoting between safe, standard semi-automatic, and forced reset semi-automatic modes.
  • In standard mode, the disconnector catches the hammer after a shot, requiring a manual trigger release to reset.
  • In forced reset mode, the cam forces the trigger to reset, and the safety selector prevents the disconnector from catching the hammer, enabling immediate subsequent firing.

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 prior art forced reset triggers designed for one firearm platform (e.g., the AR15) are often inoperable in others (e.g., the AR10) due to differences in component dimensions and geometry. (’784 Patent, col. 1:20-32). Specifically, a locking member tall enough to be actuated by an AR10’s bolt carrier would physically interfere with the underside of that same carrier as it cycles rearward, rendering the firearm inoperable. (’784 Patent, col. 1:37-44).
• The Patented Solution: The invention is a trigger locking member featuring an "upwardly extending deflectable portion." (’784 Patent, col. 5:5-10). This upper portion is constructed to be rigid when pushed from the rear by the bolt carrier moving into battery (which unlocks the trigger), but it is also designed to "deflect or fold" downward and rearward when contacted from above by the bolt carrier cycling to the rear. (’784 Patent, col. 1:46-52, col. 3:52-col. 4:2). This one-way hinging action allows the locking member to function without causing interference.
• Technical Importance: This innovation allows forced reset trigger technology to be adapted for use across multiple semi-automatic firearm platforms with different internal geometries. (Compl. ¶19).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶¶41, 43). The right to assert other claims is also reserved. (Compl. ¶41).
• Essential elements of claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • The locking member is movable between a first (locked) and second (unlocked) position.
  • 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.

III. The Accused Instrumentality

Product Identification

The complaint accuses the Three-Position “Atrius Forced Reset Selektor” (“First Infringing Device”) and the (3-position) “Super Safety” (“Second Infringing Device”). (Compl. ¶21).

Functionality and Market Context

The complaint alleges that both accused devices are aftermarket trigger mechanisms for AR-15 pattern firearms. (Compl. ¶¶22-23). They are alleged to provide the user with the ability to switch between a safe position, a standard semi-automatic mode (referred to as "disconnector mode"), and a forced reset semi-automatic mode that uses a cam. (Compl. ¶¶22-23). The complaint alleges the Defendant sells these devices through its physical storefronts. (Compl. ¶24).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The analysis may focus on whether the accused "Atrius Super Selektor" or "Super Safety," which appear to integrate the cam and safety selector functions, meets the claim limitation of a "safety selector" that "prevents" the disconnector from catching the hammer hook. The question will be whether the accused integrated component performs this function in the manner disclosed and claimed in the patent.
  • Technical Questions: A central factual question may be whether the accused device’s cam lobe actually "forces" the trigger member toward the set position through mechanical interaction with the bolt carrier as required by the claim. The complaint’s diagrams illustrate this alleged interaction. (Compl. p. 14).

’784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute will likely center on the proper construction of "deflectable portion that is separately movable relative to the body portion." The question for the court will be whether this phrase, in light of the patent's disclosure of a one-way hinge, can read on the specific design and operation of the accused products' lever arm.
  • Technical Questions: An evidentiary question will be whether the accused device's lever arm actually functions by being "separately movable" to avoid interference with a cycling bolt carrier, or if it achieves a similar result through a different, non-infringing mechanical principle.

V. Key Claim Terms for Construction

’247 Patent: "safety selector preventing the disconnector hook from catching said hammer hook"

• The Term: "safety selector preventing the disconnector hook from catching said hammer hook"
• Context and Importance: This functional language in claim 15 defines how the "forced reset" mode is mechanically achieved. The method of "preventing" the disconnector's operation is central to distinguishing the forced reset mode from the standard semi-automatic mode.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses the functional term "preventing" without specifying a particular structure. A plaintiff may argue that any mechanism tied to the safety selector's position that achieves this outcome falls within the claim's scope.
  • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where a "narrow semi-circular portion 116" of the selector physically blocks the disconnector from pivoting. (’247 Patent, col. 8:59-65, Fig. 6B). A defendant may argue that this disclosed mechanism limits the scope of "preventing" to direct physical obstruction.

’784 Patent: "deflectable portion that is separately movable relative to the body portion"

• The Term: "deflectable portion that is separately movable relative to the body portion"
• Context and Importance: This phrase captures the core innovation of the ’784 Patent—solving the bolt carrier interference problem. The interpretation of "deflectable" and "separately movable" will determine whether the patent covers only specific hinged designs or a broader category of solutions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language does not explicitly require a "hinge" or "pivot." The Summary of the Invention describes the solution as an extension that "deflects or folds." (’784 Patent, col. 1:48-52). This could suggest that mechanisms other than a pin-and-hole hinge are contemplated.
  • Evidence for a Narrower Interpretation: Both detailed embodiments in the specification show a distinct upper portion that pivots on a transverse pin relative to the main body, incorporating a spring to bias it into the extended position. (’784 Patent, col. 3:41-49; col. 4:39-45; Figs. 2-4, 8-10). A defendant may argue that "separately movable" should be construed to require such a discrete, multi-part pivoting structure.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. It alleges inducement based on Defendant’s alleged acts of "encouraging, advertising, promoting, and instructing others" to use the accused products. (Compl. ¶¶30, 45). It alleges contributory infringement on the basis that the accused components are "specially designed and adapted to be used in a fire control unit to forcibly reset a trigger mechanism" and are not suitable for substantial non-infringing use. (Compl. ¶¶32, 47).
• Willful Infringement: The complaint alleges that Defendant's infringement is willful, asserting that Defendant "has known or should have known" its actions infringed the patents, at least as of the filing of the complaint. (Compl. ¶¶33, 48). The complaint characterizes the alleged infringement as "egregious" and undertaken despite an "objectively high likelihood" of infringement. (Compl. ¶¶33, 48).

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

1. A core issue for the ’247 Patent will be one of functional operation: Do the accused products’ integrated cam/selector mechanisms perform the claimed function of "preventing" the disconnector from engaging the hammer in the same way as the invention claimed in the patent, or is there a fundamental mismatch in their mode of operation?
2. The central dispute for the ’784 Patent will be one of definitional scope: Can the term "deflectable portion that is separately movable," which is described in the patent's embodiments as a discrete, one-way hinge, be construed to cover the specific mechanical design of the accused products' upper lever arm?
3. A key evidentiary question for both patents will be contributory infringement: Can the plaintiffs demonstrate that the accused trigger components have no substantial non-infringing use, given that they are alleged to be part of a multi-mode system that includes a standard semi-automatic function?