ABC IP LLC v. Nguyen

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Steven Thanh Nguyen, d/b/a Polymer Pew (Texas)
  • Plaintiff’s Counsel: Adams and Reese LLP; Wood Herron & Evans LLP
• Case Identification: 4:25-cv-02961, S.D. Tex., 06/26/2025
• Venue Allegations: Venue is alleged to be proper in the Southern District of Texas because the Defendant, an individual, resides and/or has a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendant’s sale of components for firearm trigger mechanisms constitutes indirect infringement of a patent related to a selectable, dual-mode (standard and forced-reset) trigger system.
• Technical Context: The technology concerns firearm trigger mechanisms, specifically "forced reset triggers" designed to increase the potential rate of fire in semiautomatic firearms by using the firearm's action to mechanically reset the trigger.
• Key Procedural History: Plaintiffs allege that counsel sent Defendant a cease and desist letter on March 31, 2025, providing notice of the patent-in-suit and accusing the "Super Safety" product of infringement. This notice forms the basis for the willfulness allegation.

Case Timeline

Date	Event
2022-09-08	Priority Date for U.S. Patent No. 12,038,247
2024-07-16	U.S. Patent No. 12,038,247 Issued
2025-03-31	Plaintiffs' counsel sent cease and desist letter to Defendant
2025-06-26	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,038,247 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,038,247, "Firearm Trigger Mechanism", issued July 16, 2024.

The Invention Explained

• Problem Addressed: The patent addresses the desire among some firearm users to increase the rate of semiautomatic fire beyond what is typically possible with a standard trigger, where the user must consciously release the trigger to reset the mechanism for the next shot (Compl. ¶17; ’247 Patent, col. 1:41-43). Prior art methods like "bump firing" or trigger systems requiring modified bolt carriers are presented as having drawbacks (’247 Patent, col. 1:44-65).
• The Patented Solution: The invention is a trigger mechanism, particularly for AR-pattern firearms, that provides two user-selectable modes: a standard semiautomatic mode and a "forced reset" mode (Compl. ¶19; ’247 Patent, Abstract). In the forced reset mode, the rearward movement of the firearm's bolt carrier during the firing cycle acts on a pivoting cam, which in turn "forces the trigger member to the set position" (’247 Patent, Abstract). This mechanical reset allows a user to fire consecutive shots more rapidly, as it bypasses the need to manually release the trigger to reset the sear (’247 Patent, col. 2:55-65).
• Technical Importance: The mechanism is designed as a "drop-in" replacement module that can be installed in popular firearm platforms using standard assembly pins without requiring modification to other core components like the bolt carrier (’247 Patent, col. 2:23-26).

Key Claims at a Glance

• The complaint asserts independent Claim 15 (Compl. ¶35).
• The essential elements of Claim 15 include:
  • A hammer, a trigger member, and a disconnector, each adapted for mounting in a firearm receiver.
  • A movably mounted cam with a lobe, movable between a first position and a second position.
  • In the second position, the cam lobe "forces said trigger member towards said set position."
  • A "standard semi-automatic mode" where the cam is in its first position, the disconnector catches the hammer after firing, and the user must manually release the trigger to reset the mechanism.
  • A "forced reset semi-automatic mode" where the cam is in its second position, the cycling bolt carrier causes rearward pivoting of the hammer, and the disconnector hook is "prevented from catching said hammer hook."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• Defendant’s "Super Safety" (3 Position) device and associated components, sold via the Polymer Pew website and other channels (Compl. ¶¶ 21-22).

Functionality and Market Context

• The complaint alleges that Defendant does not sell a complete, assembled trigger mechanism, but rather a kit of specialized parts (Compl. ¶23). These parts allegedly include a "specially made cam and cam lever" that replaces a standard safety selector, and a "trigger member specially cut to work with the cam" (Compl. ¶23). When these components are installed in an AR-pattern firearm receiver along with a standard hammer and disconnector, the resulting assembly allegedly "creates the invention of the ’247 Patent" (Compl. ¶23). The complaint further alleges Defendant sells an "AR15 Trigger Display Model," which illustrates how to combine the sold parts into an allegedly infringing assembly (Compl. ¶25). This display model shows the accused components fully assembled in a transparent housing (Compl. p. 8).

IV. Analysis of Infringement Allegations

Claim Chart Summary

• The complaint provides a detailed chart with diagrams alleging that the "Super Safety" device, when assembled as intended, infringes Claim 15 of the ’247 patent. The diagram from the complaint at page 13, for instance, illustrates the alleged interaction of the cam lobe with the trigger member (Compl. p. 13).

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a hammer having a sear catch and a hook for engaging a disconnector and adapted to be mounted in a fire control mechanism pocket of a receiver...	The Infringing Device is installed with a standard hammer that has a sear catch and a hook for engaging a disconnector.	¶36, p. 10	col. 7:49-53
a trigger member having a sear and adapted to be mounted in the fire control mechanism pocket...	The Infringing Device is installed with a trigger member in the fire control mechanism pocket.	¶36, p. 11	col. 7:50-56
wherein said sear and sear catch are in engagement in said set positions... and are out of engagement in said released positions...	The sear and sear catch are in engagement when the hammer and trigger are in their set positions.	¶36, p. 12	col. 7:56-59
said disconnector having a hook for engaging said hammer and adapted to be mounted in the fire control mechanism pocket...	The disconnector is adapted to be mounted in the fire control mechanism pocket and has a hook for engaging the hammer.	¶36, p. 12	col. 7:63-65
a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, said cam being movable between a first position and a second position, in said second position said cam lobe forces said trigger member towards said set position,	The Infringing Device has a movable cam with a cam lobe. In the second position, the cam lobe allegedly forces the trigger member toward the set position.	¶36, p. 13	col. 14:46-51
whereupon in a standard semi-automatic mode, said cam is in said first position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook... a user must manually release said trigger member...	In standard mode, the cam is in a first position, and after firing, the disconnector hook catches the hammer hook, requiring a manual trigger release to reset.	¶36, p. 14	col. 14:5-21
and whereupon in a forced reset semi-automatic mode, said cam is in said second position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook... the user can pull said trigger member to fire...	In forced reset mode, the cam is moved to a second position. The complaint provides a diagram alleging that rearward hammer movement occurs such that the disconnector hook does not catch the hammer hook, allowing the user to fire again without manual release.	¶36, pp. 14-15	col. 14:22-34

Identified Points of Contention

• Scope Questions: This is an indirect infringement case. A central issue for the court will be whether Defendant's components are "staple article[s] or commodit[ies] of commerce suitable for substantial noninfringing use" (35 U.S.C. § 271(c)). The complaint alleges the components are "especially made or especially adapted" for an infringing use (Compl. ¶¶ 27, 37). The existence of substantial non-infringing uses for the specialized cam and precut trigger will be a primary focus.
• Technical Questions: A key factual question is whether the combination of Defendant's kit with standard AR-15 parts functionally performs every limitation of Claim 15. The analysis may focus on whether the "disconnector hook is prevented from catching said hammer hook" in the forced reset mode, as the claim requires. The complaint's diagrams illustrate this theory, but how the accused parts achieve this prevention will be subject to technical evidence and expert testimony (Compl. p. 14).

V. Key Claim Terms for Construction

• The Term: "forces said trigger member towards said set position"
• Context and Importance: This term is the functional core of the "forced reset" concept. The definition of "forces" will be critical to determining infringement. Practitioners may focus on this term because the dispute could center on whether the accused device’s cam merely contacts the trigger or whether it effectuates a positive, overriding mechanical action that meets the "force" requirement as defined by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the interaction generally, stating that as the cam pivots, "the cam lobe 78 may acts upon the cam follower 58 to pivot the trigger member 38" (’247 Patent, col. 9:18-20). This language could suggest that any pivoting action caused by the cam meets the limitation.
  • Evidence for a Narrower Interpretation: The patent also states that the action of the bolt carrier "thereby forces the hammer 36 and trigger member 38 to their set positions" (’247 Patent, col. 9:54-56). This language, which describes the ultimate result of the cam's action, could support a narrower construction requiring a definitive reset of the trigger mechanism, sufficient to overcome any contrary pressure from the user's finger.

VI. Other Allegations

• Indirect Infringement: The complaint exclusively pleads indirect infringement.
  • Contributory Infringement (§ 271(c)): Plaintiffs allege Defendant sells components that are a material part of the patented invention, know they are especially made for infringement, and that they are not staple articles of commerce with substantial noninfringing uses (Compl. ¶¶ 26-27, 37).
  • Induced Infringement (§ 271(b)): Plaintiffs allege Defendant instructs customers on how to assemble the components into an infringing configuration, thereby inducing infringement (Compl. ¶¶ 29, 38). The allegation that Defendant sells a "display model" demonstrating the final assembly is presented as evidence of this intent (Compl. ¶25).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringing activities after receiving a cease and desist letter on March 31, 2025, which allegedly provided actual notice of the ’247 Patent and the infringement allegations (Compl. ¶¶ 14, 33).

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

• A core issue will be one of indirect liability: given that Defendant sells components and not a fully assembled firearm, can Plaintiffs prove that the "Super Safety" components have no substantial non-infringing use and that Defendant specifically intended for its customers to assemble them into an infringing configuration? The sale of the "display model" and any accompanying instructions will be central to this inquiry.
• Another key question will be one of functional operation: does the accused assembly, when constructed from Defendant's kit and standard parts, actually perform the specific mechanical functions recited in Claim 15? The court will need to determine whether the accused cam truly "forces" the trigger to reset and, critically, whether it reliably "prevent[s] the disconnector hook from catching said hammer hook" in the forced reset mode, or if there is a mismatch in technical operation.