DCT

1:26-cv-00018

ABC IP LLC v. Peak Tactical LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00018, D. Wyo., 01/15/2026
  • Venue Allegations: Venue is asserted based on Defendants residing and/or having a regular and established place of business within the District of Wyoming.
  • Core Dispute: Plaintiff alleges that Defendant’s "Disruptor" forced reset trigger assembly infringes four U.S. patents related to firearm trigger mechanisms that use the cycling of a bolt carrier to reset the trigger.
  • Technical Context: The technology at issue involves "forced reset triggers" (FRTs) for AR-pattern semiautomatic firearms, which are designed to enable a faster rate of fire compared to standard trigger mechanisms.
  • Key Procedural History: The complaint alleges Defendant Norton is acting in concert with an individual, Douglas Rios, who was subject to a permanent injunction in a prior litigation involving one of the patents-in-suit ('’223 Patent). The complaint also alleges Defendants demonstrated knowledge of the asserted patents before the suit through public forum posts and by hosting a "Legal Library" on their website that included copies of the patents.

Case Timeline

Date Event
2017-09-29 Priority Date for ’223 Patent
2019-12-24 ’223 Patent Issued
2022-01-10 Priority Date for ’003, ’336, and ’807 Patents
2023-08-15 ’003 Patent Issued
2024-07-16 ’336 Patent Issued
2025-04-15 ’807 Patent Issued
2025-09-13 Defendant allegedly demonstrates knowledge of patent rights in forum post
2025-12-15 Alleged launch date for Accused Product
2025-12-23 Date of related case mentioned in complaint (D. Ariz.)
2026-01-07 Defendant allegedly demonstrates continued intent to infringe in forum post
2026-01-15 Complaint Filed

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

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

The Invention Explained

  • Problem Addressed: The patent’s background section describes the limitations of standard semiautomatic triggers, where the rate of fire is constrained by how quickly a user can manually release and reset the trigger after each shot. It notes that prior methods to increase firing rates, like "bump firing," are imprecise, while other mechanical solutions are often complex, expensive, or not easily retrofitted into popular firearm platforms like the AR-15 (’223 Patent, col. 1:17-54).
  • The Patented Solution: The invention is a "drop-in" trigger mechanism that uses the firearm's natural action cycle to reset the trigger automatically. As the bolt carrier moves rearward after a shot, it pushes the hammer back into a cocked position; this movement of the hammer, in turn, makes physical contact with the trigger member and forces it back to the reset position (’223 Patent, col. 2:38-44). To prevent the hammer from falling before the bolt is safely back in battery ("hammer follow"), a pivotable "locking bar" blocks the trigger from being pulled until it is disengaged by the bolt carrier returning to its forward, in-battery position (’223 Patent, Abstract; Fig. 5).
  • Technical Importance: This approach provides a self-contained, drop-in module to increase the potential rate of semiautomatic fire without modifying the firearm's receiver or bolt carrier, distinguishing it from solutions that require more extensive modification (’223 Patent, col. 2:30-38).

Key Claims at a Glance

  • The complaint asserts independent Claim 4.
  • Essential elements of Claim 4 include:
    • A housing with openings for hammer and trigger pins.
    • A hammer and trigger member that pivot between set and released positions.
    • A surface on the trigger member positioned to be contacted by the hammer during the action cycle, causing the trigger member to be forced to the set position.
    • A pivotally mounted locking bar that is spring-biased to a first position where it mechanically blocks the trigger member from moving to the released position.
    • The locking bar is movable to a second, un-blocked position when contacted by the bolt carrier reaching a "substantially in-battery position," allowing the trigger to be pulled again.

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

The Invention Explained

  • Problem Addressed: While forced reset triggers increase the potential rate of fire, there may be a desire to operate the firearm in a conventional semiautomatic mode as well. The patent builds on prior forced-reset technology by introducing selectivity (’003 Patent, col. 2:17-23).
  • The Patented Solution: The invention provides a trigger mechanism with a three-position safety selector that allows the user to choose between "safe," "standard semi-automatic," and "forced reset semi-automatic" modes (’003 Patent, Abstract). In the standard mode, a disconnector functions conventionally to catch the hammer, requiring the user to manually release the trigger to reset it. In the forced reset mode, the safety selector physically prevents the disconnector from engaging the hammer, allowing the forced reset sequence (where the hammer resets the trigger) to occur unimpeded (’003 Patent, col. 4:1-14).
  • Technical Importance: This design integrates both conventional and forced-reset functionalities into a single drop-in module, controlled by the firearm’s safety selector, offering greater versatility to the user (’003 Patent, col. 2:33-39).

Key Claims at a Glance

  • The complaint asserts independent Claim 4.
  • Essential elements of Claim 4 include:
    • A housing, hammer, trigger member, disconnector, and locking member, many of which are similar to the components 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 operation in standard semi-automatic mode, where the disconnector hook catches the hammer hook, requiring a manual trigger release.
    • A second "whereupon" clause describing operation in forced reset mode, where the safety selector prevents the disconnector hook from catching the hammer hook, allowing for a subsequent trigger pull without a manual release once the bolt is in battery.

U.S. Patent No. 12,036,336 - *"Firearm Trigger Mechanism,"* issued July 16, 2024

  • Technology Synopsis: This patent, a continuation of the application leading to the ’003 Patent, also describes a trigger mechanism with a three-position safety selector for safe, standard semi-automatic, and forced reset semi-automatic modes. It details the mechanical interactions that allow the selector to enable a conventional disconnector in one mode and disable it in another to permit the forced reset function (’336 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent Claim 3 (Compl. ¶77).
  • Accused Features: The complaint alleges that the "Disruptor" trigger, with its three-position safety selector and dual-mode functionality, infringes this patent (Compl. ¶¶77, 79).

U.S. Patent No. 12,274,807 - *"Firearm Trigger Mechanism,"* issued April 15, 2025

  • Technology Synopsis: This patent, a continuation of the application leading to the '336 Patent, further refines the claims for a trigger mechanism having a three-position safety selector. The claims focus on the combination of elements including a hammer, trigger, disconnector, locking member, and the selector that governs the interaction between them to provide selectable standard and forced-reset modes (’807 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent Claim 1 (Compl. ¶91).
  • Accused Features: The complaint alleges that the "Disruptor" trigger’s integrated system of a three-position selector controlling a dual-mode trigger mechanism infringes this patent (Compl. ¶¶91, 93).

III. The Accused Instrumentality

  • Product Identification: The accused product is a firearm trigger assembly known as the "Disruptor" (Compl. ¶24).
  • Functionality and Market Context: The complaint alleges the Disruptor is a "forced reset trigger assembly" designed for the AR-15 platform (Compl. ¶24). According to product descriptions cited in the complaint, the Disruptor features a "three-position safety selector with Safe, Semi-Automatic, and Enhanced Semi-Automatic modes" (Compl. ¶26, Ex. F). The complaint asserts that these modes correspond to safe, standard semi-automatic with a disconnector, and forced reset semi-automatic modes (Compl. ¶29). The complaint provides a plaintiff-generated rendering of the Disruptor's internal components, illustrating its hammer, trigger, locking bar, and disconnector (Compl. p. 16). The defendants are alleged to have marketed the product through online forums and a dedicated website with links to retailers (Compl. ¶¶25-28).

IV. Analysis of Infringement Allegations

’223 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
For a firearm having a receiver with a fire control mechanism pocket, assembly pin openings in side walls of the pocket, and a bolt carrier that reciprocates and pivotally displaces a hammer when cycled, a trigger mechanism, comprising: The accused Disruptor device is an AR-pattern trigger designed for a firearm with these features. ¶51 col. 2:30-35
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins; The Disruptor includes a housing with the claimed openings for hammer and trigger pins. ¶51 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 Disruptor includes a hammer with a sear notch that pivots on a transverse axis as claimed. ¶51 col. 4:11-29
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions, The Disruptor includes a trigger member with a sear that pivots on a transverse axis as claimed. ¶51 col. 3:50-59
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 hammer of the Disruptor allegedly pivots rearward and contacts a surface on the trigger member, forcing the trigger member to its set position. ¶51 col. 5:27-38
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, The Disruptor includes a pivotally mounted locking bar that, in its first position, mechanically blocks the trigger member. ¶51 col. 4:60-6:3
and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved by an external force to the released position. The locking bar is movable to a second position when contacted by the bolt carrier, allowing the trigger member to be pulled. The complaint provides a diagram illustrating the locking bar in the first, mechanically blocked position (Compl. p. 20). ¶51 col. 4:60-5:6
  • Identified Points of Contention:
    • Scope Questions: The preamble of Claim 4 recites a trigger mechanism "For a firearm having..." certain features. A potential question is how this preamble limits the claim, which is directed to the trigger mechanism itself rather than the entire firearm system.
    • Technical Questions: A key factual question may be whether the "locking bar" in the accused device operates as claimed. The analysis will depend on evidence showing it is spring-biased to a blocking position and is moved to a non-blocking position only upon contact by the bolt carrier when it reaches a "substantially in-battery position."

’003 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
A firearm trigger mechanism comprising: a housing having a first pair of transversely aligned openings... and a second pair... for receiving a trigger member pin, The Disruptor is a firearm trigger mechanism that includes a housing with the claimed aligned openings. ¶65 col. 7:45-8:2
a hammer having a sear catch and a hook for engaging a disconnector and mounted in said housing to pivot on said hammer pin between set and released positions... The Disruptor includes a hammer with a sear catch and hook, mounted to pivot as claimed. ¶65 col. 8:3-7
a trigger member having a sear... said trigger member having a surface positioned to be contacted by a surface of said hammer during rearward pivoting... to cause said trigger member to be forced to said set position... The Disruptor's trigger member is allegedly forced to a set position by contact with the hammer during rearward pivoting. ¶65 col. 10:14-23
a disconnector having a hook for engaging said hammer and mounted in said housing to pivot on said trigger member pin, The Disruptor includes a disconnector with a hook mounted to pivot on the trigger member pin. ¶65 col. 8:22-28
a locking member mounted in said housing to pivot on a transverse locking member pin... pivotable between a first position at which said locking member mechanically blocks said trigger member... and a second position... allowing said trigger member to be moved... The Disruptor includes a locking member that pivots between a first (blocked) position and a second (unblocked) position. ¶65 col. 8:29-50
a safety selector adapted to be mounted... to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions, The Disruptor includes a three-position safety selector that pivots between safe, standard semi-automatic, and forced reset modes. ¶65 col. 9:11-23
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... In its standard semi-automatic mode, the Disruptor’s disconnector hook allegedly catches the hammer hook, requiring a manual trigger release to fire again. ¶65 col. 10:39-53
whereupon in said forced reset semi-automatic position... said safety selector preventing said disconnector hook from catching said hammer hook... In its forced reset mode, the safety selector allegedly prevents the disconnector from catching the hammer. The complaint includes a diagram showing the "set position" where the disconnector is held away from the hammer (Compl. p. 35). ¶65 col. 10:1-13
  • Identified Points of Contention:
    • Scope Questions: The functional language in the final "whereupon" clauses is critical. The claim requires the safety selector itself to be the agent that prevents the disconnector from catching the hammer. The dispute may turn on whether the accused selector performs this specific function, or if the prevention is an indirect result of other component interactions.
    • Technical Questions: An evidentiary question will be whether the accused product's "standard semi-automatic" mode operates as claimed, specifically requiring a user to "manually release said trigger member to free said hammer." The precise mechanical interactions between the safety selector and the disconnector in each of the three positions will be a central point of factual inquiry.

V. Key Claim Terms for Construction

For the ’223 Patent:

  • The Term: "locking bar"
  • Context and Importance: This component is central to the patent's safety feature, preventing out-of-battery firing. Its definition will be critical to determining infringement, as the accused device must have a structure that meets the specific functional and structural limitations associated with this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim describes the bar functionally as being "pivotally mounted... and spring biased... in which [it] mechanically blocks the trigger member." Parties may argue this covers any pivotable, spring-loaded component that performs this blocking function, regardless of its specific shape.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the locking bar is carried on a frame and has an upper end that extends above the housing to be engaged by the bolt carrier (’223 Patent, col. 4:60-67). Figure 3 shows this specific arrangement (locking bar 62, frame 66), which could be used to argue for a narrower construction tied to this disclosed structure.

For the ’003 Patent:

  • The Term: "said safety selector preventing said disconnector hook from catching said hammer hook"
  • Context and Importance: This functional language in Claim 4 defines the core of the "forced reset" mode's operation. Infringement will hinge on whether the accused safety selector is the direct cause of this "preventing" action. Practitioners may focus on this term because it links the selector's position to a specific mechanical outcome.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "preventing" should be construed broadly to mean that the selector's position creates a state or condition in which the disconnector cannot engage the hammer, even if the selector does not directly touch the disconnector.
    • Evidence for a Narrower Interpretation: The specification states that in the forced reset position, "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. 9:24-28). This suggests a specific mechanism—stopping the disconnector from pivoting—which could support a narrower construction requiring direct or indirect contact between the selector and the disconnector body itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement based on Defendants’ website providing instructional materials, including videos, that allegedly instruct customers on how to install and use the accused "Disruptor" trigger in a manner that directly infringes the asserted patents (Compl. ¶¶52, 66, 80, 94). Contributory infringement is alleged on the basis that the trigger assembly is specially designed for infringing use and is not a staple article suitable for substantial noninfringing use (Compl. ¶¶54, 68, 82, 96).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge of the patents. The complaint cites Defendants' website, which allegedly includes a "FRT Legal Library" page linking to copies of the ’223, ’003, and ’336 patents (Compl. ¶33). It also cites public forum posts from September 2025 and January 2026 where Defendants allegedly acknowledged Plaintiffs' patent rights and the "inevitable lawsuit" (Compl. ¶¶34-35).

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

  • A central issue will be one of functional operation: Does the accused "Disruptor" trigger's safety selector directly perform the function of "preventing said disconnector hook from catching said hammer hook," as required by claims in the ’003, ’336, and ’807 patents, or does it achieve a similar result through a mechanically distinct method that falls outside the claim scope?
  • A key question of claim scope will be whether the "locking bar" of the ’223 patent can be construed to read on the corresponding safety mechanism in the accused device, which will depend on the precise mechanical interaction between that component, the trigger, and the bolt carrier.
  • A significant question for damages and potential enhancement will be one of intent: Do the Defendants' alleged pre-suit statements in public forums and the "Legal Library" on their website constitute sufficient evidence to meet the standard for willful infringement, suggesting they proceeded to market the Disruptor despite a known or obvious risk of infringing valid patents?