ABC IP LLC v. Mister Guns LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiffs: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendants: Mister Guns, LLC (Texas), Thomas Carter II (individual), and Brandi Carter (individual)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 2:26-cv-00056, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiffs allege venue is proper in the Eastern District of Texas because Defendants have committed acts of infringement and maintain regular and established places of business within the district.
• Core Dispute: Plaintiffs allege that Defendants’ “Three-Position Atrius Forced Reset Selektor” infringes two patents related to selectable, forced-reset trigger mechanisms for semiautomatic firearms.
• Technical Context: The technology concerns firearm trigger mechanisms that use the cycling of the firearm's action to mechanically reset the trigger, enabling a significantly faster rate of fire than is possible with standard semi-automatic triggers.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history between the parties.

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 an improved mechanism for increasing the rate of fire in a semi-automatic firearm, moving beyond techniques like "bump firing" or prior forced-reset trigger designs for which further improvement is desired (’247 Patent, col. 1:41-54, 1:15-16). Standard triggers require a user to manually release and reset the trigger between shots, which limits firing speed (’247 Patent, col. 1:26-34).
• The Patented Solution: The invention is a selectable trigger mechanism that integrates three modes: "safe," "standard semi-automatic," and "forced reset semi-automatic" (’247 Patent, Abstract). The system uses a pivoting cam that, when in the forced-reset mode, is actuated by the rearward movement of the bolt carrier to mechanically force the trigger back to its set position (’247 Patent, col. 2:55-65). A key aspect is the role of the safety selector, which in the standard mode allows the disconnector to function normally but, in the forced-reset mode, prevents the disconnector from catching the hammer, thereby enabling the forced reset cycle (’247 Patent, col. 3:1-10).
• Technical Importance: This design offers users the flexibility to switch between a conventional semi-automatic operation and an accelerated forced-reset operation within a single, integrated "drop-in" module (Compl. ¶ 19; ’247 Patent, col. 2:24-26).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶ 26).
• Claim 15 recites a firearm trigger mechanism comprising:
  • A hammer, a trigger member, and a disconnector.
  • A cam that is movable between a first position (for standard mode) and a second position (for forced reset mode).
  • In the second position, a cam lobe forces the trigger member toward its set position.
  • In a standard semi-automatic mode, the disconnector hook catches the hammer hook.
  • In a forced reset semi-automatic mode, the cam is in the second position, and the disconnector hook is 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. ¶ 26).

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

• Issued: July 9, 2024

The Invention Explained

• Problem Addressed: The patent identifies a geometric incompatibility problem when adapting a forced-reset trigger from one firearm platform (e.g., an AR15) to another with different dimensions (e.g., an AR10) (’784 Patent, col. 1:21-31). A locking member made tall enough to be actuated by the AR10's bolt carrier would physically interfere with the front portion of that same carrier as it cycles rearward, rendering the mechanism inoperable (’784 Patent, col. 1:37-44).
• The Patented Solution: The invention discloses a trigger locking member with a "deflectable" or "one-way folding" upper extension (’784 Patent, col. 1:46-52). This extension is rigid when pushed from the rear by the bolt carrier moving into battery (which unlocks the trigger), but it pivots or folds backward when contacted from the front by the reciprocating bolt carrier, thus avoiding interference (’784 Patent, col. 4:26-39). The design allows the locking member to be sufficiently tall for actuation in various firearm geometries without creating a mechanical conflict.
• Technical Importance: This innovation allows a core forced-reset trigger design to be adapted for use across multiple firearm platforms with different internal dimensions, overcoming a key limitation of prior art designs (Compl. ¶ 20).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶ 40).
• Claim 1 recites an extended trigger member locking device for a forced reset trigger mechanism, comprising:
  • 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 is comprised of 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. ¶ 40).

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

The complaint alleges the accused product is a firearm trigger component that allows a user to select between three operational modes: safe, standard semi-automatic (referred to as "disconnector mode"), and forced reset semi-automatic (referred to as "cam modes") (Compl. ¶ 23). The selection is allegedly made by rotating the device, which functions as a safety selector (Compl. ¶ 23). The complaint alleges Defendants market and sell the device through physical storefronts (Compl. ¶ 24). A plaintiff-generated rendering shows the accused device installed in a lower receiver. (Compl. p. 19).

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be the meaning of "prevented from catching." The claim requires that in forced reset mode, the disconnector hook is "prevented from catching said hammer hook." The analysis may focus on whether the accused device achieves this by physically blocking the disconnector, or by forcing the trigger to reset so quickly that the disconnector is functionally, but not physically, prevented from engaging the hammer.
• Technical Questions: What evidence does the complaint provide that the accused device operates in two distinct modes that map directly onto the "first position" and "second position" of the claimed cam? The dispute may center on whether the accused device's mechanics for switching modes and resetting the trigger align with the specific sequence of operations described in Claim 15.

’784 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: Does the phrase "separately movable relative to the body portion" require a distinct hinge or pivot, as shown in the patent's embodiments, or could it be construed more broadly to cover a component that flexes or bends? The interpretation of this term appears central to the infringement analysis.
• Technical Questions: Does the accused "Atrius Super Selektor" actually contain a component that functions as a one-way hinge, deflecting to allow the bolt carrier to pass rearward while remaining rigid for actuation as the carrier moves forward? The complaint's renderings illustrate this theory, but the actual mechanical operation of the accused device will be a critical factual question.

V. Key Claim Terms for Construction

For the ’247 Patent

• The Term: "prevented from catching said hammer hook" (Claim 15)
• Context and Importance: This phrase defines the core functionality of the "forced reset" mode. The infringement determination will depend on whether the accused device's method of operation falls within the scope of this functional language. Practitioners may focus on this term because the mechanism of how prevention is achieved (e.g., physical blocking vs. timing) is a likely point of technical dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is functional and does not specify a particular structure for achieving the prevention. The abstract similarly states "the safety selector preventing the disconnector hook from catching the hammer hook," which could be read to cover any form of prevention effectuated by the selector's position (’247 Patent, Abstract).
  • Evidence for a Narrower Interpretation: Dependent claim 2 recites a "protuberance" on the safety selector that "contacts said disconnector preventing" the hook from catching. A defendant may argue this suggests the independent claim should be interpreted as requiring a similarly direct, physical prevention mechanism.

For the ’784 Patent

• The Term: "separately movable relative to the body portion" (Claim 1)
• Context and Importance: This limitation describes the novel feature of the invention—the one-way folding extension that solves the geometric interference problem. Whether the accused device’s components exhibit this specific type of relative movement will be dispositive for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the feature as an "upward extension portion that is separately movable relative to the body portion" and later refers to a "one-way hinge feature that causes the locking member to pivot" or "deflect or fold" (’784 Patent, col. 1:62-65, col. 2:5-7). This language may support an interpretation that covers various forms of separate movement, not just a specific type of hinge.
  • Evidence for a Narrower Interpretation: The detailed description and figures consistently depict this feature as a distinct part (22) that pivots on a pin (24) relative to the body (26) (’784 Patent, Fig. 2; col. 4:39-44). A defendant may argue that "separately movable" should be limited to this disclosed two-piece, hinged embodiment.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. Inducement is based on allegations that Defendants encourage and instruct customers on how to use the infringing device (Compl. ¶¶ 29-30, 43-44). Contributory infringement is based on allegations that the components are "specially designed and adapted to be used" in an infringing manner and are not suitable for substantial non-infringing use (Compl. ¶¶ 31, 45).
• Willful Infringement: Willfulness is alleged for both patents based on the assertion that Defendants "have known or should have known" their actions constituted infringement, at least as of the filing and service of the complaint (Compl. ¶¶ 32, 46).

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

• A core issue will be one of functional mechanism: For the ’247 patent, does the accused device operate by actively "preventing" the disconnector from engaging the hammer, as claimed, or does it achieve an accelerated rate of fire through a different technical pathway that falls outside the claim's specific functional requirements?
• A central question will be one of structural equivalence: For the ’784 patent, does the accused device’s locking member incorporate a "deflectable portion that is separately movable relative to the body portion," or is it a unitary component whose motion, while complex, does not meet the two-part, relative-movement limitation central to the patent?
• An overarching evidentiary question will be one of factual operation: Do the plaintiff's computer-generated renderings, which form the basis of the infringement allegations, accurately depict the real-world mechanical operation of the accused "Atrius Super Selektor" when installed and used in a firearm?