ABC IP LLC v. Superior Firearms Of Texas

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Superior Firearms of Texas, LLC (Texas)
  • Plaintiff’s Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 2:26-cv-00058, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business within the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiffs allege that Defendant’s "Atrius Forced Reset Selektor" infringes two patents related to selectable, forced reset trigger mechanisms for semi-automatic firearms.
• Technical Context: The technology at issue involves firearm trigger mechanisms designed to mechanically force the trigger to reset after firing, enabling a significantly faster rate of semi-automatic fire than is possible with standard trigger designs.
• Key Procedural History: The complaint identifies ABC IP, LLC as the patent owner by assignment and Rare Breed Triggers, Inc. as the exclusive licensee. No other significant procedural events, such as prior litigation or administrative challenges involving the patents-in-suit, are mentioned.

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 the desire among some firearm users to increase the rate of semi-automatic fire, a function limited by standard trigger mechanisms that require a user to manually release the trigger to reset it for a subsequent shot. The patent notes the existence of prior "forced reset" triggers and states that "Further improvement... is desired" (’247 Patent, col. 2:14-15; Compl. ¶15-17).
• The Patented Solution: The patent discloses a trigger mechanism with a three-position safety selector for "safe," "standard semi-automatic," and "forced reset semi-automatic" modes ('247 Patent, Abstract). In the standard mode, a disconnector catches the hammer after a shot, requiring a manual trigger release to reset the mechanism. In the forced reset mode, the cycling of the firearm's bolt carrier actuates a cam that forces the trigger member back to its set position, while the safety selector simultaneously prevents the disconnector from engaging the hammer. This allows for immediate subsequent firing without the user needing to release the trigger ('247 Patent, col. 2:54-68).
• Technical Importance: The invention provides a user-selectable, "drop-in" trigger module that can alternate between conventional semi-automatic operation and a mode that mechanically facilitates a higher rate of fire by actively resetting the trigger ('247 Patent, col. 2:24-28).

Key Claims at a Glance

• The complaint asserts independent claim 15 ('247 Patent, col. 14:15-15:16; Compl. ¶25).
• Claim 15 recites a firearm trigger mechanism comprising:
  • A hammer, a trigger member, a disconnector, and a cam.
  • A safety selector for pivoting between standard and forced reset semi-automatic modes.
  • In the "standard" mode, the cycling bolt carrier causes the disconnector hook to catch the hammer hook, requiring a manual trigger release to fire again.
  • In the "forced reset" mode, the cycling bolt carrier causes the cam to force the trigger to its set position, while the disconnector hook is "prevented from catching" the hammer hook, allowing the user to fire again without a manual release.
• The complaint reserves the right to assert additional 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's background section explains that forced reset triggers designed for one firearm platform (e.g., an AR15) may be geometrically incompatible with a related but dimensionally different platform (e.g., an AR10). An upward-extending locking member might be too short to be actuated by the bolt carrier in one platform, but if lengthened, it could interfere with the bolt carrier's movement in another (’784 Patent, col. 1:20-44).
• The Patented Solution: The invention is a trigger locking member with an "upwardly extending deflectable portion" ('784 Patent, Abstract). This extension is designed to be rigid when pushed from the rear by the bolt carrier as it returns to battery, thereby actuating the trigger mechanism as intended. However, when contacted from the front by the bolt carrier as it cycles to the rear, the extension is designed to "deflect or fold" out of the way, preventing interference ('784 Patent, col. 1:46-51, Figs. 5-7).
• Technical Importance: This design allows a single forced reset trigger mechanism to be compatible with multiple firearm platforms that have different internal dimensions and bolt carrier geometries, overcoming a key limitation of prior designs (Compl. ¶19).

Key Claims at a Glance

• The complaint asserts independent claim 1 ('784 Patent, col. 5:12-6:10; Compl. ¶39).
• Claim 1 recites a trigger member locking device for a forced reset trigger mechanism, comprising:
  • A locking member movable between a first (locked) and second (unlocked) position.
  • The locking member has a "body portion" that is movably supported.
  • The locking member also has an "upwardly extending deflectable portion" that is "separately movable" relative to the body portion between an extended and deflected position.
• The complaint reserves the right to assert additional claims (Compl. ¶39).

III. The Accused Instrumentality

Product Identification

• The "Three-Position 'Atrius Forced Reset Selektor'" (the "Infringing Device") (Compl. ¶21).

Functionality and Market Context

• The complaint alleges the accused product is a forced reset trigger mechanism that allows a user to switch between "safe, standard semiautomatic with disconnector, and forced reset semiautomatic with cam modes" by rotating a safety selector (Compl. ¶22). It is alleged to embody the technology of both asserted patents, functioning as both a selectable-mode trigger and an extended trigger member locking device (Compl. ¶¶21, 41). The complaint includes a photograph of the accused product's selector lever (Compl. p. 6).
• The product is allegedly sold at the Defendant's physical storefronts (Compl. ¶23).

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,038,247 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be the interpretation of the term "prevented." The analysis will examine whether the accused device's safety selector, in the forced reset mode, physically blocks or otherwise "prevents" the disconnector from catching the hammer, or if it achieves a similar result through a mechanism that falls outside the scope of this term.
  • Technical Questions: The complaint relies on plaintiff-generated renderings to illustrate the internal operations of the accused device (Compl. p. 7). A key factual question will be whether these renderings accurately depict the physical structure and mechanical function of the actual Atrius Super Selektor, specifically concerning the interaction between the cam, trigger, and disconnector in both operational modes.

U.S. Patent No. 12,031,784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute may focus on the meaning of "separately movable." The analysis will question whether the alleged movement of the accused device's lever arm relative to its body meets the claimed structural and functional relationship, particularly as the patent specification illustrates this concept with a distinct hinge and pivot pin ('784 Patent, Figs. 2-4).
  • Technical Questions: What evidence does the complaint provide that the "lever arm" and the "body portion" of the accused device are, in fact, separate components capable of independent movement? The infringement allegation hinges on this specific mechanical configuration, which will require examination of the physical product.

V. Key Claim Terms for Construction

From the ’247 Patent, Claim 15:

• The Term: "prevented from catching"
• Context and Importance: This phrase is critical as it defines the core functional distinction between the claimed "standard" and "forced reset" modes. The outcome of the case may depend on whether the accused device's mechanism of disconnector non-engagement in its forced-reset mode constitutes "prevention."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Abstract describes the function more broadly, stating the user can fire "without manually releasing the trigger member." This focus on the ultimate outcome could support a construction that covers any mechanism achieving that result.
  • Evidence for a Narrower Interpretation: The Abstract explicitly states "the safety selector preventing the disconnector hook from catching the hammer hook." Further, the summary of invention states, "the safety selector preventing the disconnector hook from catching the hammer hook" (’247 Patent, col. 3:4-5). This language suggests the "safety selector" itself must be the agent of prevention, potentially narrowing the claim's scope.

From the ’784 Patent, Claim 1:

• The Term: "separately movable"
• Context and Importance: This term is central to the patent's asserted novelty, which is a two-part locking member that solves a cross-platform compatibility problem. Infringement will turn on whether the accused device's lever and body are "separately movable" or if they function as a single, integrated component.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the function as an extension that "deflects or folds to avoid interfering contact" ('784 Patent, col. 1:48-50). This functional description could support a broader meaning of "separately movable" that includes flexing or bending, not just pivoting.
  • Evidence for a Narrower Interpretation: The detailed description of the preferred embodiment shows the "foldable extension portion 22" pivoting on its own transverse pivot pin (24), distinct from the pivot pin (20) for the main locking bar body (26) ('784 Patent, col. 3:39-44). The figures reinforce this two-pivot design, which could support a narrower construction requiring a distinct, hinged movement.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement for both patents, based on Defendant's alleged "encouraging, advertising, promoting, and instructing others to use and/or how to use the Infringing Device" (Compl. ¶¶28, 42). It also alleges contributory infringement, asserting that the components of the accused device are not suitable for substantial non-infringing use because they are "specially designed and adapted to be used in a fire control unit to forcibly reset a trigger mechanism" (Compl. ¶¶30, 44).
• Willful Infringement: For both patents, the complaint alleges willfulness based on Defendant's alleged knowledge of the patents, at a minimum, from the date of the complaint's filing. It asserts that Defendant "could not reasonably or subjectively believe" that its actions do not constitute infringement or that the patents are invalid (Compl. ¶¶31, 45).

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

• A core issue will be one of functional operation: For the ’247 Patent, does the accused device's safety selector perform the specific claimed function of "preventing" the disconnector from catching the hammer in its "forced reset" mode, or does it operate via a different mechanical principle that achieves a similar outcome?
• A key question will be one of structural interpretation: For the ’784 Patent, can the accused device's lever arm be considered "separately movable" from its body, as that term is defined by the patent's specification and figures which emphasize a distinct hinging mechanism?
• An overarching evidentiary question will be the accuracy of the complaint's visual aids: How faithfully do the plaintiff-generated, color-coded diagrams depict the actual physical construction and mechanical operation of the commercially available "Atrius Forced Reset Selektor," upon which the infringement allegations for both patents heavily rely?