ABC IP LLC v. Ar TT LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: AR-TT, LLC, d/b/a Takedown Tools (Washington); Clausen Inc. (Washington); Jonathan Clausen (individual); and Jodi Clausen (individual)
  • Plaintiff’s Counsel: Dunn & Black, P.S.
• Case Identification: 2:26-cv-00014, E.D. Wash., 01/13/2026
• Venue Allegations: Plaintiffs allege venue is proper because Defendants reside in the judicial district and/or have committed acts of infringement and maintain a regular and established place of business there.
• Core Dispute: Plaintiffs allege that Defendants’ “Partisan Disruptor” firearm trigger mechanism infringes four patents related to forced reset trigger technology.
• Technical Context: The technology at issue involves mechanical trigger systems for AR-platform semi-automatic firearms designed to use the force of the firearm’s reciprocating bolt carrier to reset the trigger, a design which can enable a higher rate of fire compared to conventional trigger mechanisms.
• Key Procedural History: The complaint alleges that a website associated with the manufacturer of the accused device includes a page titled “FRT Legal Library” that links to copies of the ’223, ’003, and ’336 patents, which Plaintiffs present as evidence of Defendants’ pre-suit knowledge of the asserted patents.

Case Timeline

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

U.S. Patent No. 10,514,223 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 10,514,223, "Firearm Trigger Mechanism," issued December 24, 2019. (Compl. ¶12).

The Invention Explained

• Problem Addressed: The patent’s background section describes a desire among firearm users to increase the rate of semi-automatic fire and notes the drawbacks of existing methods like "bump firing" or complex trigger systems. (ʼ223 Patent, col. 1:26-55). It specifically identifies a need for a "drop-in" solution that does not require modification of other standard firearm components, such as the bolt carrier. (ʼ223 Patent, col. 2:20-29).
• The Patented Solution: The invention is a trigger mechanism, adaptable as a "drop-in" module, where the normal rearward cycling of the bolt carrier forces the hammer into its cocked position. (ʼ223 Patent, col. 2:30-44). During this movement, a surface on the hammer makes contact with a corresponding surface on the trigger member, which forcibly pushes the trigger to its reset position. (ʼ223 Patent, col. 5:35-41). A separate "locking bar" blocks the trigger from being pulled again until the bolt carrier has returned to a safe, "in-battery" position, a feature designed to prevent malfunctions such as "hammer follow." (ʼ223 Patent, col. 2:40-44; Fig. 5).
• Technical Importance: This approach provides a mechanical method to achieve a rapid trigger reset using existing, unmodified firearm components beyond the trigger group itself. (ʼ223 Patent, col. 2:30-38).

Key Claims at a Glance

• The complaint asserts independent Claim 4. (Compl. ¶35).
• The essential elements of Claim 4 include:
  • A housing for the trigger mechanism components.
  • A hammer mounted in the housing to pivot between set and released positions.
  • A trigger member mounted in the housing to pivot, having a surface positioned to be contacted by the hammer during cycling, causing the trigger member to be "forced to the set position."
  • A "locking bar" that is pivotally mounted and spring-biased to mechanically block the trigger member from moving to the released position.
  • The locking bar is movable to a second, un-blocking position when contacted by the bolt carrier as it reaches a "substantially in-battery position," which then allows the trigger to be moved by an external force.

U.S. Patent No. 11,724,003 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 11,724,003, "Firearm Trigger Mechanism," issued August 15, 2023. (Compl. ¶13).

The Invention Explained

• Problem Addressed: The complaint characterizes this invention as an enhancement of the forced-reset technology, adding the ability to select different operating modes. (Compl. ¶24). The patent background reiterates the desire for increased rates of fire and states that "further improvement in forced reset triggers is desired." ('003 Patent, col. 2:21-22).
• The Patented Solution: This patent adds a disconnector and a three-position safety selector to the forced-reset design. (ʼ003 Patent, Abstract). This allows the user to select one of three modes: safe, standard semi-automatic, or forced reset semi-automatic. In the standard mode, the disconnector engages the hammer as it would in a conventional trigger mechanism. (ʼ003 Patent, col. 9:19-30). In the forced reset mode, the safety selector is configured to interact with the disconnector, "preventing the disconnector hook from catching the hammer hook," which allows the hammer-to-trigger forced reset interaction to occur without interference from the disconnector. (ʼ003 Patent, col. 9:31-43).
• Technical Importance: The invention claims to provide a single trigger mechanism that offers the user the choice between a conventional semi-automatic operation and a forced-reset operation. (Compl. ¶24).

Key Claims at a Glance

• The complaint asserts independent Claim 4. (Compl. ¶43).
• The essential elements of Claim 4 include:
  • A housing, hammer, trigger member, disconnector, and locking member, which interact to create a forced-reset function similar to that in the ’223 Patent.
  • A "safety selector" adapted to pivot between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • A "whereupon" clause describing the standard mode, where the disconnector hook catches the hammer hook, requiring a manual trigger release by the user to reset.
  • A "whereupon" clause describing the forced reset mode, where the bolt carrier's movement forces the trigger to reset and the "safety selector prevent[s] said disconnector hook from catching said hammer hook."

U.S. Patent No. 12,036,336 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024. (Compl. ¶14).
• Technology Synopsis: This patent describes a firearm trigger mechanism with selectable operational modes, building upon the technology in the '003 patent. The invention combines a forced-reset mechanism with a traditional disconnector and a three-position safety selector, allowing the user to choose between standard semi-automatic fire and forced-reset semi-automatic fire. (Compl. ¶24; '336 Patent, Abstract). A key aspect is the safety selector's role in disabling the disconnector's ability to catch the hammer when the forced-reset mode is selected. ('336 Patent, col. 4:6-14).
• Asserted Claims: Independent Claim 3. (Compl. ¶50).
• Accused Features: The complaint alleges that the "Partisan Disruptor" infringes by providing selectable modes for safe, standard semi-automatic operation with a disconnector, and forced reset semi-automatic operation. (Compl. ¶¶30, 51).

U.S. Patent No. 12,274,807 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025. (Compl. ¶15).
• Technology Synopsis: This patent also claims a trigger mechanism with selectable modes of operation for an AR-pattern firearm. The system integrates a hammer, trigger, disconnector, locking bar, and a three-position safety selector. (’807 Patent, Abstract). The configuration allows the user to switch between a standard semi-automatic mode, where the disconnector functions conventionally, and a forced-reset mode, where the cycling of the bolt carrier resets the trigger and the disconnector is prevented from interfering. (Compl. ¶24; '807 Patent, Abstract).
• Asserted Claims: Independent Claim 1. (Compl. ¶57).
• Accused Features: The complaint accuses the "Partisan Disruptor" of infringing by using a three-position selector to switch between a standard "disconnector mode" and a "forced reset" mode. (Compl. ¶¶30, 58).

III. The Accused Instrumentality

Product Identification

The accused product is the "(3-Position) 'Partisan Disruptor'" trigger mechanism. (Compl. ¶26).

Functionality and Market Context

The complaint describes the accused product as a "Forced-Reset Drop-In Cassette Trigger FRT" intended for the AR-15 firearm platform, sold via the website "www.artakedowntool.com". (Compl. ¶¶27, 37). A product screenshot shows the "Partisan Forced-Reset Drop-In Cassette Trigger FRT." (Compl. ¶29). The product is allegedly sold as a standalone component or pre-installed in a firearm receiver. (Compl. ¶28). Functionally, it is alleged to operate in three modes selected by the user: safe, standard semi-automatic with a disconnector, and forced reset semi-automatic. (Compl. ¶30).

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,514,223 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "substantially in-battery position" reads on the precise point in the accused device's operational cycle at which its locking bar is moved. The timing of this interaction is critical to both the infringement analysis and the safe functioning of the mechanism.
  • Technical Questions: What evidence does the complaint provide that the accused device's hammer-trigger interaction performs the specific function of forcing the trigger to the "set position" as required by the claim? The analysis will depend on the specific geometry and mechanics of the accused parts.

U.S. Patent No. 11,724,003 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Does the accused safety selector's interaction with the disconnector constitute "preventing" it from catching the hammer hook, as the claim requires? The method of this prevention (e.g., direct physical blocking versus indirect repositioning) may be a point of dispute.
  • Technical Questions: The infringement analysis will turn on whether the accused device's mechanism, when in "standard semi-automatic" mode, functions as claimed, specifically requiring a user to "manually release said trigger member to free said hammer from said disconnector."

V. Key Claim Terms for Construction

From the ’223 Patent (Claim 4)

• The Term: "substantially in-battery position"
• Context and Importance: This term defines the timing requirement for when the locking bar disengages to permit the next shot. Its construction is critical because it dictates how close the bolt carrier must be to a fully closed and locked state before the trigger can be pulled. A broader definition might cover a wider range of the bolt's forward travel, while a narrower one would require it to be almost or completely locked.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The use of the word "substantially" suggests the position is not required to be perfectly or completely "in-battery," allowing for some degree of tolerance. The patent does not provide an explicit numerical or geometrical definition, which may support giving the term its plain and ordinary meaning.
  • Evidence for a Narrower Interpretation: The patent states that the locking bar's function is to prevent "'hammer follow' behind the bolt or bolt carrier." ('223 Patent, col. 2:42-44). The specification also describes the final step as preventing release of the hammer "before the bolt is completely locked and in-battery." ('223 Patent, col. 6:65-col. 7:1). This language may support an interpretation that "substantially" means a position where the firearm is safely locked and ready to fire, which would be a very narrow window at the end of the bolt carrier's travel.

From the ’003 Patent (Claim 4)

• The Term: "preventing said disconnector hook from catching said hammer hook"
• Context and Importance: This functional language is central to the distinction between the standard and forced-reset modes. Infringement will depend on whether the accused safety selector performs this "preventing" function. Practitioners may focus on this term because the mechanism of prevention (e.g., direct blocking versus indirect interference) will be a key technical question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses broad functional language ("preventing"), which could be argued to cover any mechanism that results in the disconnector failing to engage the hammer, regardless of the specific mechanical cause.
  • Evidence for a Narrower Interpretation: The detailed description explains that in the forced-reset mode, a "narrow semi-circular portion 116 permits the trigger blade 54 to be pulled but prevents the disconnector 60 from pivoting with the trigger member 38." ('003 Patent, col. 9:31-35). This suggests a specific mechanism—physically stopping the disconnector's pivot—which could support a narrower construction limited to direct mechanical obstruction.

VI. Other Allegations

Indirect Infringement

The complaint makes a general statement alleging direct, contributory, and induced infringement. (Compl. ¶18). However, the enumerated counts (Counts I-IV) are explicitly for "Direct Infringement" only, and the complaint does not plead specific facts to support the knowledge and intent elements required for induced or contributory infringement claims. (Compl. pp. 9, 13, 20, 27).

Willful Infringement

Willfulness is alleged for all four asserted patents. (Compl. ¶¶40, 47, 54, 61). The complaint bases this allegation on alleged pre-suit notice, citing a webpage titled "FRT Legal Library" maintained by "Partisan Triggers" (identified as the manufacturer) that allegedly links to copies of the ’223, ’003, and ’336 patents. (Compl. ¶19).

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

• A core issue will be one of mechanical functionality: Do the internal components of the accused "Partisan Disruptor" interact in the specific manner and sequence required by the asserted claims? The case will likely involve detailed expert analysis of whether the accused device’s safety selector physically "prevents" disconnector engagement as claimed, or if a different mechanical principle is at work.
• The dispute may also turn on a definitional question: How is the term "substantially in-battery position" to be construed? The interpretation of this term will establish a critical timing window that the accused device's operation must fall within to infringe the '223 patent.
• A key evidentiary question will surround willfulness: Can Plaintiffs establish that the "FRT Legal Library" webpage provided legally sufficient pre-suit notice of the patents-in-suit to the named Defendants, thereby supporting the allegations of knowing and willful infringement?