ABC IP v. HK Parts

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: HK PARTS INC. (Utah)
  • Plaintiff’s Counsel: Parsons Behle & Latimer
• Case Identification: 2:26-cv-00090, D. Utah, 02/04/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant has a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s aftermarket firearm triggers, which feature a "forced reset" capability, infringe two patents related to selectable, multi-mode trigger mechanisms.
• Technical Context: The technology at issue involves mechanical trigger systems for semiautomatic firearms, specifically designs that use the firearm's natural cycling action to reset the trigger, potentially allowing for a faster rate of fire.
• Key Procedural History: The complaint notes that Plaintiff ABC IP, LLC is the owner of the asserted patents and Plaintiff Rare Breed Triggers, Inc. is the exclusive licensee. No other significant procedural events, such as prior litigation between the parties or administrative patent challenges, are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 12,038,247 - “FIREARM TRIGGER MECHANISM,” issued Jul. 16, 2024

The Invention Explained

• Problem Addressed: The patent background discusses a desire to increase the rate of fire in semiautomatic firearms Compl. ¶¶15-17 It notes that prior art devices for achieving a "forced reset" of the trigger often required modification of other core components of the firearm, such as the bolt carrier, limiting their use as simple "drop-in" replacements ’247 Patent, col. 1:56-63
• The Patented Solution: The patent describes a trigger module with a three-position safety selector that allows the user to choose between "safe," "standard semi-automatic," and "forced reset semi-automatic" modes ’247 Patent, abstract In the forced reset mode, a cam, which is pivoted by the rearward movement of the bolt carrier, pushes the trigger member back to its set position ’247 Patent, col. 2:56-61 Concurrently, a feature on the safety selector shaft physically prevents the disconnector from engaging the hammer, which would otherwise halt the firing sequence until the user manually released the trigger ’247 Patent, col. 8:55-65 This combination allows the firearm to be fired again as soon as the action cycles, without the user needing to manually let the trigger move forward.
• Technical Importance: The invention provides a self-contained, "drop-in" trigger module that enables a forced reset function using a standard, unmodified bolt carrier, broadening its applicability to a wide range of existing AR-pattern firearms ’247 Patent, col. 2:18-27

Key Claims at a Glance

• The complaint asserts independent Claim 15 Compl. ¶29
• The essential elements of Claim 15 include:
  • A firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a cam.
  • The cam is movable between a first position (used in standard mode) and a second position (used in forced reset mode) where its lobe forces the trigger member toward its set position.
  • In a "standard semi-automatic mode," the cam is in the first position, and the disconnector hook catches the hammer hook after a shot, requiring the user to manually release the trigger to reset the mechanism for the next shot.
  • In a "forced reset semi-automatic mode," the cam is in the second position, and the rearward movement of the bolt carrier pivots the hammer, but the disconnector hook is "prevented from catching" the hammer hook, allowing the user to pull the trigger again immediately after the bolt returns to battery.
• The complaint states Plaintiffs may assert infringement of other claims in addition to Claim 15 Compl. ¶29

U.S. Patent No. 12,031,784 - “ADAPTED FORCED RESET TRIGGER,” issued Jul. 9, 2024

The Invention Explained

• Problem Addressed: The patent describes a problem in adapting forced reset trigger mechanisms across different firearm platforms, such as from an AR15 to a larger AR10 ’784 Patent, col. 1:21-28 Due to dimensional differences, a locking member that works in one platform may be too short to be actuated by the bolt carrier in another; if simply lengthened, it may then interfere with the bolt carrier as it cycles to the rear ’784 Patent, col. 1:36-44
• The Patented Solution: The invention is a trigger locking device featuring an "upwardly extending deflectable portion" that acts as a one-way hinge ’784 Patent, abstract ’784 Patent, col. 2:62-65 This portion is rigid when pushed from the rear by the bolt carrier returning to battery, allowing it to unlock the trigger as intended. However, when the bolt carrier moves rearward during cycling, it contacts the extension from the front, causing it to deflect or fold out of the way, thus avoiding interference ’784 Patent, col. 3:52-60 ’784 Patent, Fig. 7
• Technical Importance: This design allows a single conceptual trigger mechanism to be adapted for firearms with varied internal geometries and component spacing, enhancing its versatility across different weapon platforms ’784 Patent, col. 1:45-52

Key Claims at a Glance

• The complaint asserts independent Claim 1 Compl. ¶50
• The essential elements of Claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • A locking member movable between a first "locked" position and a second "unlocked" position.
  • The locking member has a movably supported "body portion" and an "upwardly extending deflectable portion."
  • Crucially, this deflectable portion is "separately movable relative to the body portion" between an "extended position" and a "deflected position."
• The complaint reserves the right to assert other claims from the ’784 Patent Compl. ¶50

III. The Accused Instrumentality

Product Identification

• The complaint names two accused products: the "Three-Position 'AR-15 Super Safety - Forced Reset Selector'" (the "First Infringing Device") and the "Three-Position 'ARC-Fire Trigger'" (the "Second Infringing Device") Compl. ¶¶21, 25

Functionality and Market Context

• The complaint alleges that both products are aftermarket trigger assemblies sold on Defendant's website, https://hkparts.net Compl. ¶¶22, 26 According to website descriptions cited in the complaint, the devices are designed for AR-15 style firearms and provide the user with three selectable modes: "SAFE, SEMI, and FULL SEMI" Compl. ¶24 Functionally, they are alleged to provide both a standard, disconnector-based semiautomatic mode and a "forced reset" mode that uses a "mechanically leveraged reset" action Compl. ¶¶24, 27 The complaint includes a screenshot from Defendant's website showing one of the accused products for sale Compl. ¶23

IV. Analysis of Infringement Allegations

’247 Patent Infringement Allegations

• Identified Points of Contention:
  • Functional Questions: The core of the infringement allegation for the ’247 patent rests on the dual-mode functionality. A key question for the court will be whether the accused products' selector mechanism, when in the "forced reset" mode, performs the specific function of preventing the disconnector hook from catching the hammer hook, as required by the claim. The complaint’s color-coded renderings illustrate this alleged operation Compl. ¶31, p. 15 The defense may focus on arguing that its mechanism operates differently or that the disconnector is not "prevented" from catching the hammer in the manner claimed.

’784 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute over the ’784 patent may center on the scope of the term "separately movable." The complaint provides an overlay graphic alleging that the accused device's lever arm has "total separate travel" from its body Compl. ¶52, p. 39 The central question will be whether the accused device's construction meets this claim limitation. A defendant could argue its product is a unitary, flexible component that merely bends, rather than having a "deflectable portion" that is "separately movable" from its "body portion" as taught in the patent's hinged embodiments.

V. Key Claim Terms for Construction

• Term from the ’247 Patent: "prevented from catching"

  • Context and Importance: This phrase in Claim 15 defines the key distinction between the claimed "standard" and "forced reset" modes. The outcome of the infringement analysis for this patent will likely depend on whether the accused device's operation in its highest rate-of-fire mode falls within the court's construction of this functional language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is functional and does not specify a particular structure or method for "preventing" the catch. A party might argue that any mechanism that achieves this result—whether by blocking, disabling, or holding the disconnector—infringes.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where a "narrow semi-circular portion 116" of the safety selector "prevents the disconnector 60 from pivoting," thereby preventing the catch ’247 Patent, col. 8:55-61 A party could argue the term should be limited to this disclosed mechanism of physically blocking the disconnector's movement.

• Term from the ’784 Patent: "separately movable relative to the body portion"

  • Context and Importance: This language in Claim 1 is the structural heart of the invention, distinguishing it from a simple, one-piece flexible lever. Practitioners may focus on this term because the infringement question turns on whether the accused device's lever arm has a distinct movement relative to its base, or if it is a single component that merely flexes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not explicitly require a hinge or pivot. A party could argue that significant, independent deflection of one part of a component relative to another part constitutes "separate movement," even without a discrete mechanical joint.
    • Evidence for a Narrower Interpretation: Both embodiments described in the specification use a distinct pivot pin (pin 24, pin 54) to create a one-way hinge, explicitly allowing the extension to pivot relative to the body ’784 Patent, col. 3:40-42 col. 4:41-44 The specification also refers to a "hinging movement" ’784 Patent, col. 4:45-46, suggesting that the invention is tied to a pivoting structure, not just material flexibility.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for each patent Compl. ¶¶33, 41, 54, 62 The inducement allegations are based on Defendant's website content, which allegedly includes promotional materials, compatibility charts, installation instructions, and videos that encourage and instruct customers to install and use the accused devices in an infringing manner Compl. ¶¶34-39 ¶¶55-60 Contributory infringement is alleged on the basis that the accused devices are specially designed for infringing use and are not suitable for substantial non-infringing use Compl. ¶¶41, 62
• Willful Infringement: Willfulness is alleged for both patents. The complaint asserts that Defendant knew or should have known its actions constituted infringement and continued its conduct despite an objectively high likelihood of infringement, with knowledge established at least as of the filing of the complaint Compl. ¶¶42, 63

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

This case appears to present focused disputes on both the functional operation and structural characteristics of the accused trigger mechanisms. The key questions for the court will likely be:

• A core functional question of operational equivalence: Do the accused triggers, when set to their "forced reset" mode, operate by "preventing" the disconnector from catching the hammer as claimed in the ’247 Patent? Resolution will depend on a factual analysis of the accused mechanism and the court's construction of the claim's functional language.
• A central issue of structural scope: Does the lever arm on the accused locking devices constitute an "upwardly extending deflectable portion that is separately movable relative to the body portion" under the language of the ’784 Patent? This will likely turn on whether the court construes this term to require a distinct mechanical hinge, as shown in the patent's figures, or whether it can read on an integrated, flexible component.
• An evidentiary question of intent for indirect infringement: To what extent does the instructional and promotional material on Defendant's website direct users to assemble and operate the accused triggers in the specific multi-step configurations that are alleged to infringe the asserted claims?