Rare Breed Triggers Inc v. Dairyland Defense Solutions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Rare Breed Triggers, Inc. (Texas) and ABC IP, LLC (Delaware)
  • Defendant: Dairyland Defense Solutions, LLC (Wisconsin) and Gaven L. Poczekaj, Sr. (Wisconsin)
  • Plaintiff’s Counsel: Wood Herron & Evans LLP
• Case Identification: 2:25-cv-00852, E.D. Wis., 06/13/2025
• Venue Allegations: Venue is alleged to be proper based on the assertion that all Defendants reside in and/or have a place of business within the Eastern District of Wisconsin.
• Core Dispute: Plaintiffs allege that Defendants’ “Dairyland Defender 3 POS FRT” forced reset trigger infringes four patents related to firearm trigger mechanisms that can be forced to reset by the cycling of the firearm’s action.
• Technical Context: The technology concerns "forced reset triggers" for AR-platform firearms, which use the energy from a fired round to mechanically reset the trigger, a function that may allow for a faster rate of fire compared to standard semi-automatic mechanisms.
• Key Procedural History: The complaint includes a screenshot of a communication allegedly from Defendant Poczekaj which references a recent court victory for "Rare breed" and states that, as a result, Defendants are "no longer allowed to sell the Dairyland Defender." This communication is presented as evidence of Defendants' knowledge of Plaintiffs' rights and may be central to the willfulness allegations.

Case Timeline

Date	Event
2017-09-29	Earliest Priority Date for '223 Patent
2019-12-24	'223 Patent Issued
2022-01-10	Earliest Priority Date for '003, '336, '807 Patents
2023-08-15	'003 Patent Issued
2024-07-16	'336 Patent Issued
2024-11-13	Accused Product Announced
2024-12-09	Accused Product Offered for Preorder
2025-04-15	'807 Patent Issued
2025-06-13	Complaint Filed

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

U.S. Patent No. 10,514,223 - "Firearm Trigger Mechanism," issued December 24, 2019

The Invention Explained

• Problem Addressed: The patent identifies a desire among firearm users to increase the rate of semi-automatic fire beyond what is typically possible with a standard trigger mechanism, where the user must consciously release the trigger to allow it to reset before firing the next round ('223 Patent, col. 1:36-39). Existing solutions are described as complex, expensive, or requiring user practice to be effective ('223 Patent, col. 2:12-15).
• The Patented Solution: The patent describes a "drop-in" trigger module for an AR-pattern firearm that uses the rearward movement of the bolt carrier to force the trigger into its reset position ('223 Patent, Abstract). As the bolt carrier cycles, it pushes the hammer back, and the hammer in turn makes physical contact with the trigger member, forcing it to pivot back to the "set" position ('223 Patent, col. 5:32-39). A separate, pivotally mounted "locking bar" then blocks the trigger from being pulled again until the bolt carrier has returned to its "in-battery" (fully forward and locked) position, preventing an unsafe condition known as "hammer follow" ('223 Patent, col. 2:40-48; FIG. 5).
• Technical Importance: This approach provides a purely mechanical method to achieve a rapid-fire capability that can be retrofitted into standard firearms without requiring modification of major components like the bolt carrier ('223 Patent, col. 2:30-39).

Key Claims at a Glance

• The complaint asserts independent Claim 4 ('Compl. ¶31).
• The essential elements of Claim 4 include:
  • A housing with openings for hammer and trigger assembly pins.
  • A hammer with a sear notch, mounted to pivot.
  • A trigger member with a sear and a surface positioned to be contacted by the hammer during cycling, with the contact forcing the trigger member to the set position.
  • A pivotally mounted, spring-biased locking bar that mechanically blocks the trigger member from moving to the released position, but is movable to an un-blocked position when contacted by the bolt carrier reaching a substantially in-battery position.

U.S. Patent No. 11,724,003 - "Firearm Trigger Mechanism," issued August 15, 2023

The Invention Explained

• Problem Addressed: While forced reset triggers provide a rapid-fire capability, the patent addresses the need for a single trigger mechanism that can offer the user a choice between this mode and a standard semi-automatic mode of operation ('003 Patent, col. 2:19-22).
• The Patented Solution: The invention adds a three-position safety selector to the forced reset trigger design ('003 Patent, Abstract). This selector allows the user to choose between "safe," "standard semi-automatic," and "forced reset semi-automatic" positions ('003 Patent, col. 2:35-39). In the standard mode, a disconnector functions conventionally, catching the hammer and requiring the user to release the trigger to reset it ('003 Patent, col. 9:16-22). In the forced reset mode, the safety selector physically interacts with and "disables" the disconnector, preventing it from catching the hammer and allowing the forced reset sequence to occur as described in the '223 Patent ('003 Patent, col. 9:23-34).
• Technical Importance: This innovation provides versatility, allowing a user to select between distinct firing modes within a single, retrofittable trigger assembly without further modification to the firearm ('003 Patent, col. 2:30-35).

Key Claims at a Glance

• The complaint asserts independent Claim 4 (Compl. ¶39).
• The essential elements of Claim 4 include:
  • A housing, hammer, trigger member, disconnector, and locking member, largely similar to the '223 Patent's components.
  • A safety selector adapted to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions.
  • A "whereupon" clause detailing operation in the standard semi-automatic position, where the disconnector hook catches the hammer hook.
  • A "whereupon" clause detailing operation in the forced reset position, where the safety selector prevents the disconnector hook from catching the hammer hook, and the trigger is forced to reset.

Multi-Patent Capsule: U.S. Patent No. 12,036,336

• Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024.
• Technology Synopsis: As a continuation of the application leading to the '003 Patent, this patent describes a similar three-mode trigger mechanism. The invention centers on a safety selector that can configure the trigger to operate in either a standard semi-automatic mode with a functioning disconnector or a forced reset mode where the disconnector is prevented from engaging the hammer, allowing the bolt carrier's motion to reset the trigger ('336 Patent, Abstract; Compl. ¶21, 27).
• Asserted Claims: Independent Claim 3 (Compl. ¶46).
• Accused Features: The complaint alleges that the "Dairyland Defender 3 POS FRT" infringes by incorporating a three-position safety selector that allows a user to switch between a standard semi-automatic mode and a forced reset mode (Compl. ¶25, 27).

Multi-Patent Capsule: U.S. Patent No. 12,274,807

• Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025.
• Technology Synopsis: This patent, also in the same family, claims a trigger mechanism for an AR-pattern firearm with a three-position safety selector. The claimed device includes a hammer, trigger, disconnector, and locking member, and provides for selectable operation in standard semi-automatic or forced reset semi-automatic modes, with the selector determining whether the disconnector engages the hammer during the firing cycle ('807 Patent, Abstract; Compl. ¶21, 27).
• Asserted Claims: Independent Claim 1 (Compl. ¶53).
• Accused Features: The complaint accuses the "Dairyland Defender 3 POS FRT" of infringing by embodying the claimed combination of components, including the three-position selector for switching between firing modes (Compl. ¶25, 27).

III. The Accused Instrumentality

Product Identification

• The accused product is the "Dairyland Defender 3 POS FRT," which is described as a forced reset trigger assembly with a three-position safety selector (Compl. ¶23, 25).

Functionality and Market Context

• The complaint alleges the accused device operates in a "forced reset mode," where the cycling of the firearm's action "causes hammer contact with the trigger member to forcefully reset the hammer and trigger member" (Compl. ¶26). It is also alleged to include a "locking bar/member" to prevent the trigger from being pulled until the bolt carrier is in battery (Compl. ¶26). Critically, the product is advertised as having a selector to "seamlessly switch between three distinct fire modes: Safe, Traditional Semi-Automatic, and Forced Reset Semi" (Compl. ¶25; p. 7). A social media post screenshot shows the accused product advertised as a "3 position FRT" (Compl. p. 6). Defendants are alleged to have sold or offered for sale the device through their website and promoted it on Facebook (Compl. ¶24).

IV. Analysis of Infringement Allegations

'223 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins;	The Infringing Unit includes a housing with transversely aligned pairs of openings. An annotated photograph points to these openings (Compl. p. 10).	¶33	col. 3:36-43
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The Infringing Unit includes a hammer with a sear notch, mounted to pivot in the housing (Compl. p. 10).	¶33	col. 4:25-28
a trigger member having a sear and...a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position;	The Infringing Unit includes a trigger member with a surface positioned to be contacted by the hammer during cycling, forcing the trigger to the set position. An annotated photograph identifies the "Hammer Surface" and "Trigger Surface" (Compl. p. 11).	¶33	col. 5:32-39
a locking bar pivotally mounted in the housing and spring biased toward a first position in which the locking bar mechanically blocks the trigger member...and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position...	The Infringing Unit includes a pivotally mounted, spring-biased locking bar that blocks the trigger, and is moved to an unblocked position by contact from the bolt carrier when it reaches an in-battery position (Compl. p. 12).	¶33	col. 5:39-62

• Identified Points of Contention:
  • Technical Question: The infringement analysis for the '223 Patent will likely focus on whether the accused device's "locking bar" and its interaction with the bolt carrier performs the precise sequence of blocking and releasing functions described in the claim. While the complaint provides annotated photos, a defense may question if the timing and mechanics of the release, specifically when the bolt carrier is "substantially in-battery," are identical.

'003 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a safety selector adapted to be mounted in a fire control mechanism pocket of a receiver to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Infringing Unit includes a safety selector for pivoting between safe, standard semi-automatic, and forced reset semi-automatic positions, as shown in a photograph (Compl. p. 17).	¶40	col. 9:11-13
whereupon in said standard semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook...	The complaint alleges that in the standard semi-automatic position, the device's disconnector hook catches the hammer hook, requiring manual trigger release by the user.	¶40	col. 9:16-22
whereupon in said forced reset semi-automatic position...said safety selector preventing said disconnector hook from catching said hammer hook...	The complaint alleges that in the forced reset semi-automatic position, the safety selector prevents the disconnector hook from catching the hammer hook, allowing the forced reset to occur.	¶40	col. 9:23-29

• Identified Points of Contention:
  • Scope & Technical Question: A central issue for the '003 Patent (and its continuations) will be the interpretation of the phrase "safety selector preventing said disconnector hook from catching said hammer hook." The dispute will likely focus on the precise mechanism by which this "preventing" function is achieved in the accused device and whether that mechanism falls within the scope of the claim as construed by the court. The complaint's evidence for this element is currently conclusory; the defense will likely demand detailed proof of this specific mechanical interaction.

V. Key Claim Terms for Construction

'223 Patent

• The Term: "locking bar"
• Context and Importance: This term is the central safety feature of the single-mode trigger, preventing out-of-battery discharge. Its definition is critical because if the defendant's corresponding component does not perform the claimed blocking and releasing functions in the manner specified, infringement may be avoided. Practitioners may focus on this term to dispute whether the accused device's safety mechanism operates identically to the one claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses functional language, describing the bar as "mechanically block[ing]" the trigger and being "movable... when contacted by the bolt carrier." A plaintiff could argue any component that performs these functions infringes, regardless of its specific shape.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the locking bar (62) pivots on a pin (68), is biased by a spring (70), and has specific contact surfaces (32) ('223 Patent, FIG. 2, 5; col. 4:61-64). A defendant might argue the term should be limited to a structure that is pivotally mounted and operates in a manner consistent with the disclosed embodiment.

'003 Patent

• The Term: "safety selector preventing said disconnector hook from catching said hammer hook"
• Context and Importance: This functional language defines the core of the multi-mode invention. Infringement of the "forced reset" capability depends entirely on proving the accused selector performs this specific disabling action on the disconnector. The case may turn on whether the accused device achieves this result through the claimed mechanism or a different, unclaimed one.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is functional. Plaintiff may argue that any interaction where the selector's position causes the disconnector to be unable to engage the hammer meets this limitation.
  • Evidence for a Narrower Interpretation: The specification describes a specific mechanism: a "narrow semi-circular portion 116" of the selector "prevents the disconnector 60 from pivoting with the trigger member 38" ('003 Patent, col. 9:25-28). A defendant could argue this limitation requires the selector to act on the disconnector itself to prevent its pivot, and that other methods of disabling the connection (e.g., blocking the hammer elsewhere) would not infringe.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain separate counts for indirect infringement. The counts listed are for direct infringement under 35 U.S.C. § 271(a).
• Willful Infringement: The complaint repeatedly alleges that Defendants' infringement is willful (Compl. ¶16, 36, 43, 50, 57). The primary factual basis alleged for willfulness is pre-suit knowledge of Plaintiffs' rights. This is supported by a screenshot of an email, allegedly from Defendant Gaven Poczekaj, which explicitly references "Rare breed" and a prior "court hearing," and states, "we are no longer allowed to sell the Dairyland Defender" (Compl. ¶29; p. 8).

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

• A core issue will be one of claim construction and technical proof: For the multi-mode patents ('003, '336, '807), the case will likely turn on how the court construes the claim language "preventing said disconnector hook from catching said hammer hook." Can Plaintiffs provide sufficient technical evidence to prove that the accused selector performs this precise function, as opposed to achieving a similar outcome through a different, non-infringing mechanical pathway?
• A second key question will be one of willfulness and damages: The complaint provides unusually direct evidence of alleged knowledge in the form of an email from the defendant (Compl. p. 8). A central battleground will be whether this communication is sufficient to establish pre-suit knowledge of the specific patents-in-suit, thereby exposing Defendants to a finding of willful infringement and potential enhancement of damages.
• A final question is one of equivalence: Given the direct, side-by-side photographic comparisons in the complaint's claim charts, the infringement analysis may evolve into a granular, expert-driven debate over whether any subtle structural or functional differences between the accused product and the patent claims are substantial enough to defeat a finding of literal infringement or infringement under the doctrine of equivalents.