DCT
1:25-cv-00124
ABC IP LLC v. FRT TRIGGERS LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ABC IP, LLC (Delaware)
- Defendant: FRT TRIGGERS LLC (Wyoming)
- Plaintiff’s Counsel: Taft Stettinius & Hollister LLP
- Case Identification: 1:25-cv-00124, D. Wyo., 05/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in and has a regular and established place of business within the District of Wyoming.
- Core Dispute: Plaintiff alleges that Defendant’s “FRT-15-L3” three-position firearm trigger infringes four patents related to forced reset trigger mechanisms.
- Technical Context: The technology involves trigger mechanisms for semi-automatic firearms, specifically "forced reset triggers" that use the energy of the firearm's cycle to reset the trigger, enabling a faster rate of fire than conventional designs.
- Key Procedural History: The complaint alleges that Plaintiff sent a cease and desist letter to Defendant on July 3, 2024, identifying the ’223 and ’003 patents and accusing Defendant of infringement, which may form the basis for a subsequent willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2017-09-29 | Priority Date for ’223 Patent |
| 2019-12-24 | ’223 Patent Issued |
| 2020-12-01 | Plaintiff's Licensee launches FRT-15® trigger |
| 2022-01-10 | Priority Date for ’003, ’336, and ’807 Patents |
| 2022-01-15 | Plaintiff's Licensee demonstrates FRT-15E3™ trigger |
| 2023-08-15 | ’003 Patent Issued |
| 2024-07-03 | Plaintiff sends cease and desist letter to Defendant |
| 2024-07-16 | ’336 Patent Issued |
| 2024-08-24 | Plaintiff files intent-to-use trademark application for FRT-15L3 |
| 2025-04-15 | ’807 Patent Issued |
| 2025-05-16 | 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 describes a desire among firearm users to increase the rate of semi-automatic fire, but notes that prior art solutions like "bump firing" can be unreliable or require practice, while other mechanical solutions can be complex or expensive to install (’223 Patent, col. 1:36-col. 2:17).
- The Patented Solution: The invention is a trigger mechanism where the hammer, as it is reset by the cycling of the bolt carrier, forcibly pushes the trigger member back to its set position. A separate "locking bar" then blocks the trigger, preventing it from being pulled again until the bolt carrier is fully in battery, which prevents the hammer from accidentally "following" the bolt carrier forward without firing a round (’223 Patent, Abstract; col. 2:40-49). This reset sequence is illustrated in the patent’s Figure 5.
- Technical Importance: The technology is designed as a "drop-in" replacement module for common firearm platforms like the AR-15, allowing for an increased rate of fire without requiring modifications to other standard components like the bolt carrier (’223 Patent, col. 2:35-40).
Key Claims at a Glance
- The complaint asserts independent Claim 4.
- Essential elements of Claim 4:
- A housing with openings for hammer and trigger assembly pins.
- A hammer mounted in the housing to pivot between set and released positions.
- A trigger member mounted in the housing, having a sear and a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier, which forces the trigger member to the set position.
- A locking bar, pivotally mounted in the housing and spring-biased to a first (blocking) position, that mechanically blocks the trigger member. The locking bar is movable to a second (non-blocking) position when contacted by the bolt carrier as it reaches a "substantially in-battery position," allowing the trigger to be pulled.
- The complaint reserves the right to assert other claims, including under the doctrine of equivalents (Compl. ¶58).
U.S. Patent No. 11,724,003 - "Firearm Trigger Mechanism," issued August 15, 2023
The Invention Explained
- Problem Addressed: The patent builds on forced reset trigger technology by addressing the desire for more user-selectable firing modes within a single mechanism, noting that "further improvement in forced reset triggers is desired" (’003 Patent, col. 2:22-23).
- The Patented Solution: The invention adds a three-position safety selector to a forced reset trigger that also includes a conventional disconnector. The selector allows the user to choose between: (1) a "safe" position, (2) a "standard semi-automatic" position where the disconnector functions normally to catch the hammer, and (3) a "forced reset semi-automatic" position where the selector physically prevents the disconnector from engaging the hammer, thereby enabling the forced-reset functionality (’003 Patent, Abstract; col. 9:11-33). The interaction of the selector, disconnector, and hammer is central to its operation.
- Technical Importance: This design integrates both a conventional semi-automatic firing mode and an accelerated forced-reset mode into a single unit, giving the user the option to switch between them (’003 Patent, col. 2:35-42).
Key Claims at a Glance
- The complaint asserts independent Claim 4.
- Essential elements of Claim 4:
- A trigger mechanism in a housing, comprising a hammer, trigger member, disconnector, and locking member, similar to the ’223 Patent.
- A safety selector movable between "safe, standard semi-automatic, and forced reset semi-automatic positions."
- In the standard position, the disconnector hook catches the hammer hook, requiring a manual trigger release to reset.
- In the forced reset position, the safety selector prevents the disconnector hook from catching the hammer hook, allowing the forced reset and locking bar mechanism to control the firing cycle.
- The complaint reserves the right to assert other claims, including under the doctrine of equivalents (Compl. ¶65).
Multi-Patent Capsule
U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024
- Technology Synopsis: As a continuation of the ’003 Patent, the ’336 Patent claims a similar three-position trigger mechanism. The core technology involves a safety selector that determines whether the firearm operates in a standard semi-automatic mode (with a disconnector) or a forced reset mode (where the disconnector is disabled) (’336 Patent, Abstract).
- Asserted Claims: At least Claim 3 (independent) is asserted (Compl. ¶71).
- Accused Features: The complaint alleges the FRT-15-L3’s ability to be switched by a safety selector between a standard disconnector mode and a forced reset mode infringes the ’336 Patent (Compl. ¶¶ 53-54, 72).
U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025
- Technology Synopsis: As a further continuation in the same family, the ’807 Patent also claims a firearm trigger mechanism with a three-position selector for switching between standard and forced reset modes. It recites the key components of a hammer, trigger, disconnector, locking member, and the mode-switching safety selector (’807 Patent, Abstract).
- Asserted Claims: At least Claim 1 (independent) is asserted (Compl. ¶77).
- Accused Features: The complaint alleges the FRT-15-L3’s three-position functionality, which allows a user to select different operating modes, infringes the ’807 Patent (Compl. ¶¶ 53-54, 78).
III. The Accused Instrumentality
Product Identification
- The accused product is the "FRT-15-L3" forced reset trigger assembly (Compl. ¶51). The complaint includes a photograph of the accused FRT-15-L3 device (Compl. ¶51, p. 13).
Functionality and Market Context
- The complaint alleges the FRT-15-L3 is a "three-position" trigger assembly that incorporates the technology of the Patents-in-Suit (Compl. ¶48). It is alleged to operate by using the hammer to forcibly reset the trigger and a locking bar to prevent firing until the bolt carrier is in battery, which are features of the ’223 Patent (Compl. ¶52).
- It is further alleged to include a safety selector that allows a user to switch between a "standard disconnector semiautomatic" mode and a "forced reset semiautomatic" mode, which are features of the ’003, ’336, and ’807 Patents (Compl. ¶¶53-54). The complaint alleges the device is sold as a trigger for AR-pattern firearms (Compl. ¶60).
IV. Analysis of Infringement Allegations
The complaint alleges that the accused FRT-15-L3 device contains all the elements of the asserted claims. The complaint provides a diagram from the '003 patent family to illustrate the three-position technology (Compl. ¶42, p. 11).
’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 FRT-15L3 includes a housing with transversely aligned pairs of openings for receiving hammer and trigger assembly pins. | ¶60 | col. 3:35-44 |
| a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions; | The FRT-15L3 includes a hammer with a sear notch mounted in the housing to pivot between set and released positions. | ¶60 | col. 4:11-25 |
| a trigger member having a sear and mounted in the housing to pivot on a transverse axis...the trigger member having 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 FRT-15L3 includes a trigger member with a sear, a surface positioned to be contacted by the hammer when it is displaced by the bolt carrier, causing the trigger member to be forced to the set position. | ¶60 | col. 5:31-38 |
| 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 from moving to the released position, and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position... | The FRT-15L3 includes a locking bar that is pivotally mounted, spring biased to a first position to block the trigger, and movable to a second position when contacted by the bolt carrier as it reaches a substantially in-battery position. | ¶60 | col. 6:11-22 |
’003 Patent Infringement Allegations
| Claim Element (from Independent Claim 4) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a firearm trigger mechanism comprising: a housing... a hammer... a trigger member... a disconnector... a locking member... | The Infringing Device is a firearm trigger mechanism with a housing, hammer, trigger member, disconnector, and locking member. | ¶66 | col. 7:48 - col. 8:24 |
| and a safety selector adapted to be mounted...to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions. | The Infringing Device includes a safety selector that pivots between safe, standard semi-automatic, and forced reset semi-automatic positions. | ¶66 | col. 9:11-15 |
| whereupon in said standard semi-automatic position, rearward movement of the bolt carrier causes...said disconnector hook catches said hammer hook... | In standard semi-automatic position, the disconnector hook catches the hammer hook, requiring a user to manually release the trigger. | ¶66 | col. 9:16-24 |
| whereupon in said forced reset semi-automatic position...said safety selector prevents the disconnector hook from catching said hammer hook, and thereafter when the bolt carrier reaches the substantially in-battery position the user can pull said trigger member to fire... | In forced reset semi-automatic position, the safety selector prevents the disconnector hook from catching the hammer hook, allowing the user to fire without manually releasing the trigger after the bolt carrier returns to battery. | ¶66 | col. 9:25-33 |
- Identified Points of Contention:
- Scope Questions: A central question for the '223 Patent will be whether the accused product's "locking bar" meets the claim's functional requirements, specifically that it "mechanically blocks the trigger member" in a first position and is moved to a second, non-blocking position by contact with the bolt carrier "reaching a substantially in-battery position." The definition of "substantially in-battery" may be a point of dispute.
- Technical Questions: For the '003 patent family, a key technical question will be how the accused product's safety selector "prevents the disconnector hook from catching said hammer hook." The infringement analysis will depend on whether the accused mechanism achieves this prevention in a way that maps onto the specific structures and interactions described in the patent specification, or if it uses a technically distinct method.
V. Key Claim Terms for Construction
For the ’223 Patent
- The Term: "locking bar"
- Context and Importance: This component is the core of the invention's safety feature, preventing "hammer follow." The infringement analysis for the '223 Patent will hinge on whether the corresponding component in the FRT-15-L3 performs the specific blocking and releasing functions recited in Claim 4. Practitioners may focus on this term because its construction will define the scope of protection for the patent's primary inventive concept.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional, describing a bar that "mechanically blocks the trigger member" and is moved by the bolt carrier. A party could argue this covers any structure that performs this function, regardless of its specific shape or mounting method.
- Evidence for a Narrower Interpretation: The specification consistently describes and depicts the locking bar (62) as a distinct, pivotally mounted component that interacts with a specific "second contact surface" (32) on the trigger member (’223 Patent, col. 4:62-64; Fig. 5). A party could argue the term should be limited to this disclosed embodiment or equivalents thereof.
For the ’003 Patent
- The Term: "safety selector prevents the disconnector hook from catching said hammer hook"
- Context and Importance: This functional language is the key differentiator for the '003 patent family, defining the "forced reset" mode. The case will likely turn on whether the accused FRT-15-L3 achieves this prevention in a manner covered by the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the claim language only requires the result—prevention of the catch—and is not limited to the specific mechanism that achieves it.
- Evidence for a Narrower Interpretation: The specification describes a specific mechanism: a "narrow semi-circular portion" (116) of the safety selector (110) physically blocks the disconnector (60) from pivoting with the trigger member, thereby preventing the hook from catching the hammer (’003 Patent, col. 9:25-33). A party could argue that this detailed disclosure limits the claim scope to a selector that operates through this specific physical interaction.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain specific allegations of indirect infringement, focusing instead on Defendant's direct infringement through making, using, and selling the accused device (Compl. ¶¶ 58, 65, 71, 77).
- Willful Infringement: The complaint alleges willful infringement for all patents-in-suit. The basis for this allegation is Defendant's alleged continued infringement after receiving a cease and desist letter on July 3, 2024, which explicitly put Defendant on notice of at least the ’223 and ’003 Patents (Compl. ¶¶ 24, 56).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute centers on highly specific mechanical interactions within a firearm trigger group. The outcome will likely depend on the court’s resolution of two primary issues:
- A core issue will be one of claim construction and functional equivalence: For the ’003 patent family, does the accused FRT-15-L3’s safety selector prevent the disconnector from engaging the hammer in the specific manner described and claimed, or does it achieve a similar result through a non-infringing technical alternative?
- A key evidentiary question will be one of mechanical operation and timing: For the ’223 Patent, does the accused product’s locking mechanism meet all the functional limitations of Claim 4, particularly with respect to when and how it blocks and releases the trigger in coordination with the bolt carrier reaching a "substantially in-battery" position?