ABC IP LLC v. Hanes Tactical LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Hanes Tactical LLC (Texas) and Damion Terrell Bennett (Texas)
  • Plaintiff’s Counsel: Wood Herron & Evans LLP; Eggleston King Davis LLP
• Case Identification: 3:25-cv-00201, W.D. Tex., 01/26/2026
• Venue Allegations: Venue is alleged to be proper as Defendants reside in and/or maintain a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s "Super Safety" firearm components directly and indirectly infringe three patents related to forced reset trigger mechanisms that increase the rate of fire of semi-automatic firearms.
• Technical Context: The technology at issue involves mechanical trigger assemblies for AR-15-style firearms designed to accelerate the firing cycle by using the firearm's own action to mechanically reset the trigger after each shot.
• Key Procedural History: The complaint notes that U.S. Patent No. 7,398,723 lapsed for non-payment of a maintenance fee before being reinstated on May 16, 2022, and subsequently expired on September 22, 2024. The complaint also states that Plaintiff’s counsel sent a cease and desist letter to Defendant on March 28, 2025, specifically accusing the "Super Safety" device of infringing U.S. Patent No. 12,038,247.

Case Timeline

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 Compl. ¶12

The Invention Explained

• Problem Addressed: The patent seeks to provide an improved trigger mechanism that can increase the rate of fire of semi-automatic firearms, particularly one that can be retrofitted as a "drop-in" module into popular platforms like AR-pattern firearms and offers multiple, selectable modes of operation '247 Patent, col. 2:16-29
• The Patented Solution: The invention is a trigger assembly with a three-position safety selector allowing the user to choose between "safe," "standard semi-automatic," and "forced reset semi-automatic" modes. In the forced reset mode, the cycling of the bolt carrier actuates a pivoting cam, which in turn forces the trigger member back to its set position. A key feature is that in this mode, the safety selector mechanically prevents the disconnector from catching the hammer, enabling the user to fire again immediately upon the action closing without first having to manually release the trigger '247 Patent, Abstract col. 2:61-68
• Technical Importance: The claimed technology provides a selectable fire control group that allows an operator to switch between a conventional semi-automatic firing mode and an accelerated firing mode within a single, self-contained unit Compl. ¶22

Key Claims at a Glance

• The complaint asserts independent Claim 15 Compl. ¶47
• Essential elements of Claim 15 include:
  • A firearm trigger mechanism with a hammer, trigger member, disconnector, and a movable cam.
  • The cam is movable between a first position (for standard mode) and a second position (for forced reset mode).
  • In a "standard semi-automatic mode," the disconnector hook catches the hammer hook, requiring a manual release of the trigger by the user to fire again.
  • In a "forced reset semi-automatic mode," the cam forces the trigger to its set position, and the disconnector hook is "prevented from catching" the hammer hook, allowing the user to fire again without a manual release.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

• Patent Identification: U.S. Patent No. 12,031,784, "Adapted Forced Reset Trigger," issued July 9, 2024 Compl. ¶13

The Invention Explained

• Problem Addressed: The patent background describes how forced reset trigger mechanisms designed for one firearm platform (e.g., an AR15) may not be compatible with others (e.g., an AR10) due to different internal dimensions. Specifically, a locking member tall enough to be actuated by an AR10's bolt carrier would then interfere with a lower surface of that same carrier as it cycled rearward, rendering the device inoperable ’784 Patent, col. 1:21-44
• The Patented Solution: The invention discloses a trigger locking device with an "upwardly extending deflectable portion." This portion is rigid when pushed from the rear by the bolt carrier (to unlock the trigger) but can "deflect or fold" out of the way when contacted from the front by a lower surface of the bolt carrier during its rearward travel. This one-way yielding action avoids the interference problem described in the background ’784 Patent, Abstract col. 2:2-10
• Technical Importance: This design approach allows a forced reset trigger system to be adapted for use across multiple firearm platforms with varying internal geometries, which the patent suggests was a limitation of prior art designs Compl. ¶30

Key Claims at a Glance

• The complaint asserts independent Claim 1 Compl. ¶56
• 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 an "upward extension portion" that makes "actuating contact" with the bolt carrier to move it to the unlocked position.
  • The locking member comprises a "body portion" and an "upwardly extending deflectable portion that is separately movable relative to the body portion" between an extended and a deflected position.
• The complaint asserts that dependent claim 4 is also infringed Compl. ¶59

U.S. Patent No. 7,398,723 - "Trigger Forward Displacement System and Method"

• Patent Identification: U.S. Patent No. 7,398,723, "Trigger Forward Displacement System and Method," issued July 15, 2008 Compl. ¶14
• Technology Synopsis: The patent describes a method for accelerating the firing rate of a semi-automatic firearm by using the motion of a reciprocating part, such as the bolt carrier, to actuate a cam. In a single rotational motion, the cam simultaneously pushes the trigger forward into a ready-to-fire position and holds it there until the firearm's action is approximately closed and ready to fire again Compl. ¶¶26-27
• Asserted Claims: Claim 1 Compl. ¶66
• Accused Features: The complaint alleges that the use of the "Super Safety" device constitutes practice of the claimed method, as the device allegedly uses the reciprocating bolt carrier to cause a cam to forcibly reset the trigger, thereby accelerating the firing cycle Compl. ¶68

III. The Accused Instrumentality

Product Identification

• The "Super Safety" (3 Position) device ("the Infringing Device") Compl. ¶31

Functionality and Market Context

• The complaint alleges that Defendants sell a kit containing a "specially made cam and cam lever" and a "trigger member specially cut to work with the cam" Compl. ¶37 When installed in an AR-pattern firearm, these components allegedly create a trigger mechanism that can operate in a standard semi-automatic mode or a "forced reset semiautomatic" mode that increases the rate of fire Compl. ¶42-43 The complaint includes photographs from social media showing components of the Infringing Device offered for sale Compl. p. 8 Defendants are alleged to sell the components via Facebook posts and direct messaging Compl. ¶36

IV. Analysis of Infringement Allegations

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

Identified Points of Contention

• Scope Questions: The complaint's infringement theory relies on plaintiff-generated renderings of the accused device's internal operation Compl. p. 11 A central factual question will be whether the physical "Super Safety" device operates as depicted, particularly regarding the interaction between the safety selector and the disconnector in the "forced reset" mode.
• Technical Questions: A key technical dispute may arise over the claim limitation "disconnector hook is prevented from catching said hammer hook." The analysis will question what evidence demonstrates that the accused device actively prevents the catch via a mechanical block, as opposed to merely having the cam reset the trigger at a speed that outpaces the disconnector's ability to engage the hammer.

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

Identified Points of Contention

• Scope Questions: The case will likely focus on the meaning of "deflectable portion that is separately movable." The complaint alleges a "dovetail joint" in the accused device allows for this motion, as illustrated in a plaintiff-generated rendering showing the lever arm moving independently of the body Compl. p. 26 The dispute may question whether the degree of movement within this joint meets the "deflectable" and "separately movable" limitations as understood in the context of the patent's specification and figures, which depict distinct hinged or pivoting components.
• Technical Questions: The complaint relies on a third-party "Super Safety Guide" to describe the function of the dovetail joint Compl. p. 27 A factual question will be whether this document accurately describes the accused product's operation and whether the described "void" in the joint enables movement sufficient to be considered "deflectable" under the claim.

V. Key Claim Terms for Construction

The Term: "deflectable portion" (’784 Patent, Claim 1)

• Context and Importance: This term is central to the novelty of the ’784 Patent, which aims to solve an interference problem in prior art. The infringement allegation hinges on whether the accused device's lever arm, which connects to the body via a "dovetail joint," qualifies as a "deflectable portion." Practitioners may focus on this term because the accused mechanism appears to achieve one-way actuation through play in a joint rather than a distinct hinge or flexure point as depicted in the patent's embodiments.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification uses varied language, including "deflects or folds" and "give way" (’784 Patent, col. 2:3, col. 4:35-39). Furthermore, dependent claim 4 explicitly recites that the deflectable portion "pivots," which suggests via claim differentiation that the term "deflectable" in independent claim 1 is not limited to pivoting and could encompass other forms of movement or yielding Compl. ¶59
  • Evidence for a Narrower Interpretation: The patent’s two illustrated embodiments show a portion that moves via a separate pivot pin (Fig. 2) or a one-way hinge (Fig. 8), both of which imply a significant and distinct range of motion. A defendant may argue that "deflectable" requires this type of purpose-built, one-way articulation, not merely the incidental movement or tolerance within a dovetail joint.

The Term: "disconnector hook is prevented from catching said hammer hook" (’247 Patent, Claim 15)

• Context and Importance: This phrase defines the key mechanical distinction between the patent's "standard" and "forced reset" modes. Infringement of the forced reset aspect of the claim requires proving that the accused device actively prevents this engagement. The dispute will likely center on how this prevention is achieved.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent summary states the "safety selector preventing the disconnector hook from catching the hammer hook," which could be read broadly to cover any mechanism tied to the selector that achieves this result ’247 Patent, Abstract
  • Evidence for a Narrower Interpretation: The detailed description discloses a specific mechanism: a portion of the safety selector (116) physically "prevents the disconnector 60 from rotating with the trigger member 38," thereby blocking the hook from moving into position to catch the hammer ’247 Patent, col. 9:31-35 An accused infringer might argue the claim should be limited to this specific method of mechanical obstruction.

VI. Other Allegations

Indirect Infringement

• The complaint alleges contributory infringement and inducement for the ’247 and ’723 Patents. The factual basis is that Defendants allegedly sell components that are "especially made or especially adapted for use in an infringement" and are not staple articles of commerce Compl. ¶¶39, 49 Inducement is alleged based on Defendants instructing customers on how to assemble the components into an infringing configuration Compl. ¶¶50, 71

Willful Infringement

• Willfulness is alleged for all three patents. The complaint provides a basis for post-suit knowledge by alleging that Defendants continued to infringe after receiving a cease and desist letter on March 28, 2025, that identified the ’247 Patent and the accused "Super Safety" device Compl. ¶¶20, 45

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

• A core issue will be one of definitional scope: for the ’784 Patent, can the term "deflectable portion," which is described in the patent's embodiments as a distinct hinge or pivot, be construed to cover the alleged "separate movement" within the accused product's dovetail joint?
• A key evidentiary question will be one of functional operation: for the ’247 Patent, does the accused device's "forced reset" mode operate by actively and mechanically "preventing" the disconnector from catching the hammer, as required by Claim 15, or does it achieve a rapid reset through a different technical means?
• A third central issue will be indirect infringement: can Plaintiffs demonstrate that Defendants sold the "Super Safety" components with the specific intent to encourage infringement and knowledge that the components were not suitable for substantial non-infringing use, as required to prove inducement and contributory infringement?