ABC IP LLC v. Peak Tactical LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and RARE BREED TRIGGERS, INC. (Texas)
  • Defendant: PEAK TACTICAL, LLC d/b/a PARTISAN TRIGGERS (Wyoming) and NICHOLAS NORTON (Individual)
  • Plaintiff’s Counsel: Koch Law, P.C.
• Case Identification: 2:26-cv-00018, D. Wyo., 01/15/2026
• Venue Allegations: Venue is alleged to be proper in the District of Wyoming because Defendants reside and/or have a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendants’ "Disruptor" firearm trigger assembly infringes four patents related to forced reset trigger mechanisms.
• Technical Context: The technology involves "forced reset" triggers for semi-automatic firearms, which use the energy from the firearm's cycling action to mechanically reset the trigger, enabling a higher potential rate of fire than standard trigger mechanisms.
• Key Procedural History: The complaint alleges that an individual named Douglas Rios is bound by a permanent injunction from a prior litigation involving the ’223 Patent and that Defendant Nicholas Norton is acting in concert with Rios. The complaint also references a separate lawsuit filed in Arizona in December 2025 against other parties, where the current Defendants were allegedly named as "John Doe."

Case Timeline

Date	Event
2017-09-29	’223 Patent Priority Date
2019-12-24	’223 Patent Issue Date
2022-01-10	’003, ’336, and ’807 Patents Priority Date
2022-10-19	Permanent Injunction Entered in Prior Litigation
2023-08-15	’003 Patent Issue Date
2024-07-16	’336 Patent Issue Date
2025-04-15	’807 Patent Issue Date
2025-12-15	Alleged Accused Product Launch Date
2025-12-23	Related Arizona Lawsuit Filed
2026-01-15	Complaint Filing Date

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 background describes the desire among some firearm users to increase the rate of semi-automatic fire beyond what is possible with a standard trigger mechanism, which requires the user to manually release and reset the trigger between shots. Prior solutions to achieve this, such as "bump firing" or other mechanical devices, are described as being complex, expensive to manufacture, or not easily retrofitted into popular firearm platforms like the AR-15 (’223 Patent, col. 1:17-4, col. 2:11-29).
• The Patented Solution: The patent describes a "drop-in" trigger module that uses the firearm's natural action cycle to reset the trigger. As the bolt carrier moves rearward after a shot is fired, it forces the hammer into its cocked position. This movement of the hammer, in turn, makes physical contact with the trigger member, forcing it back to its ready-to-fire ("set") position (’223 Patent, col. 2:39-44). The invention includes a "locking bar" that prevents the trigger from being pulled again until the bolt carrier has returned to its "in-battery" position, which is a key safety feature to prevent the hammer from falling before the firearm is ready to fire (’223 Patent, Abstract; Fig. 5).
• Technical Importance: The invention purports to provide a self-contained, "drop-in" module that can be installed in standard AR-pattern firearms to enable a rapid rate of fire without requiring modification to other key components like the bolt carrier (’223 Patent, col. 2:20-29).

Key Claims at a Glance

• The complaint asserts independent Claim 4 and reserves the right to assert others (Compl. ¶49).
• Essential elements of Claim 4 include:
  • A trigger mechanism for a specified firearm type, comprising a housing, a hammer, a trigger member, and a locking bar.
  • The trigger member has a surface that is contacted by the hammer when the hammer is displaced by the cycling bolt carrier.
  • This contact "caus[es] the trigger member to be forced to the set position."
  • A locking bar is spring-biased to mechanically block the trigger member from moving.
  • The locking bar is moved out of the blocking position when contacted by the bolt carrier as it reaches a "substantially in-battery position," allowing the trigger to be pulled.

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

The Invention Explained

• Problem Addressed: The patent discloses a desire for "Further improvement in forced reset triggers," building upon the technology of mechanisms that increase the rate of fire (’003 Patent, col. 2:21-22). The problem implicitly addressed is the lack of user-selectable modes in prior forced-reset designs.
• The Patented Solution: This patent adds a "three position" safety selector to the forced reset trigger design. The selector allows the user to choose between: 1) a safe position, 2) a "standard semi-automatic" mode where a disconnector functions conventionally, and 3) a "forced reset semi-automatic" mode (’003 Patent, Abstract). In the forced reset mode, the safety selector is configured to prevent the disconnector from engaging the hammer, thereby enabling the forced-reset function, whereas in the standard mode, the disconnector is allowed to function normally (’003 Patent, col. 9:20-34).
• Technical Importance: This design offers the user the versatility of both a conventional semi-automatic trigger operation and an enhanced rate of fire via the forced-reset function within a single, integrated mechanism (Compl. ¶22).

Key Claims at a Glance

• The complaint asserts independent Claim 4 and reserves the right to assert others (Compl. ¶63).
• Essential elements of Claim 4 include:
  • A firearm trigger mechanism comprising a housing, hammer, trigger member, disconnector, locking member, and a safety selector.
  • The mechanism includes the "forced reset" feature where the hammer's movement forces the trigger to its set position.
  • It includes a safety selector that pivots between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • In the "standard" position, the disconnector hook is operative to catch the hammer hook.
  • In the "forced reset" position, the safety selector prevents the disconnector hook from catching the hammer hook, enabling the forced reset cycle to complete.

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

• Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024 (Compl. ¶12).
• Technology Synopsis: The complaint describes the technology of the ’336 Patent as being similar to the ’003 Patent, claiming a device with a selectable fire control that allows operation in either a standard semi-automatic mode with a disconnector or a forced reset semi-automatic mode (Compl. ¶22). The invention combines the forced-reset functionality with a safety selector that dictates which mode is active.
• Asserted Claims: The complaint asserts independent Claim 3 (Compl. ¶77).
• Accused Features: The complaint alleges that the Disruptor's three-position safety selector, in conjunction with its internal trigger, hammer, and disconnector components, infringes by providing selectable standard and forced-reset modes of operation (Compl. ¶79).

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

• Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025 (Compl. ¶13).
• Technology Synopsis: The complaint describes the technology of the ’807 Patent as being similar to the ’003 and ’336 patents, claiming a device with selectable fire-control modes (Compl. ¶22). The core technology is a trigger mechanism that can operate in either a conventional semi-automatic mode or a forced-reset mode, as determined by the position of a safety selector.
• Asserted Claims: The complaint asserts independent Claim 1 (Compl. ¶91).
• Accused Features: The infringement allegations target the Disruptor's complete trigger assembly, including its hammer, trigger member, disconnector, locking member, and three-position safety selector, which together are alleged to provide the claimed selectable functionality (Compl. ¶93).

III. The Accused Instrumentality

• Product Identification: The accused product is a forced reset trigger assembly known as the "Disruptor" (Compl. ¶24).
• Functionality and Market Context: The complaint alleges the Disruptor is a trigger assembly for AR-15 pattern firearms that features a three-position safety selector allowing the user to switch between "safe, standard semiautomatic with disconnector, and forced reset semiautomatic modes" (Compl. ¶29). In the forced reset mode, the cycling of the firearm's action causes contact between the hammer and trigger member, which "forcefully reset[s]" the trigger (Compl. ¶30). The complaint cites Defendants' website and forum posts on AR15.com, which promote the Disruptor to firearm consumers and retailers (Compl. ¶¶26, 28). Defendants allegedly market the product for its responsive shooting experience and hassle-free installation (Compl. ¶65, p. 25). The complaint provides an image from Defendants' website that presents the Disruptor product and its technical specifications (Compl. ¶26, p. 7).

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 Disruptor includes a housing with transversely aligned pairs of openings for receiving hammer and trigger assembly pins.	¶51, p. 15	col. 4:35-39
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The Disruptor's hammer (Blue) has a sear notch and is mounted in the housing to pivot. A plaintiff-generated, color-coded diagram illustrates the hammer and its sear notch (Compl. ¶51, p. 16).	¶51, p. 16	col. 4:11-29
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 Disruptor's trigger member (Green) has a surface positioned to be contacted by a surface of the hammer (Blue) when the hammer is displaced.	¶51, p. 18	col. 4:1-10
the contact causing the trigger member to be forced to the set position;	The rearward pivot of the hammer causes the trigger to be forced to the set position.	¶51, p. 19	col. 5:35-39
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 from moving to the released position,	The Disruptor includes a locking bar (Red) that is spring biased to a first position where it mechanically blocks the trigger member.	¶51, p. 20	col. 4:61-64
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...	The locking bar is movable to a second position when contacted by the bolt carrier, at which point the trigger member can be moved by an external force.	¶51, pp. 20-21	col. 5:55-62

• Identified Points of Contention:
  • Scope Questions: The analysis may focus on whether the term "forced to the set position" requires a specific type or degree of force, or if any mechanical action initiated by the hammer that results in a reset meets the limitation.
  • Technical Questions: A key evidentiary question may be whether the component identified as the "locking bar" in the Disruptor operates in the precise manner claimed. Specifically, what evidence shows that it moves to its second, non-blocking position "when contacted by the bolt carrier reaching a substantially in-battery position," as opposed to being actuated by a different component or at a different point in the firearm's cycle of operation?

’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... to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Disruptor includes a three-position safety selector for safe, standard semi-automatic, and "Enhanced Semi-Automatic" (i.e., forced reset) modes. The complaint includes a screenshot from the accused product's webpage describing this feature (Compl. ¶65, p. 33).	¶65, p. 33	col. 9:11-14
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,	When the Disruptor is in standard semi-automatic mode, the rearward movement of the bolt carrier causes the hammer (Blue) to pivot, and the disconnector (Orange) hook catches the hammer hook.	¶65, p. 33	col. 9:18-24
whereupon in said forced reset semi-automatic position... said safety selector preventing said disconnector hook from catching said hammer hook,	When in forced reset mode, the safety selector prevents the disconnector hook from catching the hammer hook, allowing the trigger to be forced to the set position.	¶65, p. 35	col. 9:25-34
and thereafter when the bolt carrier reaches the substantially in-battery position the user can pull said trigger member to fire the firearm without manually releasing said trigger member.	When the bolt carrier is in battery, the user can pull the trigger without first having to manually release pressure to reset the disconnector.	¶65, p. 35	col. 9:35-39

• Identified Points of Contention:
  • Scope Questions: The analysis may hinge on the construction of "preventing said disconnector hook from catching said hammer hook." Questions may arise as to whether this requires direct physical blocking of the disconnector by the selector, or if it can be read more broadly to cover any mechanism initiated by the selector's position that results in the disconnector being unable to engage the hammer.
  • Technical Questions: The complaint alleges the Disruptor's safety selector performs the claimed function. The central technical question will be what evidence demonstrates that the selector itself, or a feature of it, is the component that "prevents" the disconnector from catching the hammer in the forced reset mode, as required by the claim.

V. Key Claim Terms for Construction

The Term: "forced to the set position" (from ’223 Claim 4; ’003 Claim 4)

• Context and Importance: This phrase is the technological core of a "forced reset" trigger. Its construction will be critical to determining whether the accused device's reset mechanism infringes. Practitioners may focus on this term because the distinction between a "forced" reset, an "assisted" reset, and a standard spring-driven reset is a central issue in this technology space.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is functional, suggesting that any mechanism where hammer contact "caus[es]" the trigger to reset could be covered (’223 Patent, col. 6:39-41). The summary of the invention describes the reset broadly as being caused "by contact between the hammer and a surface of the trigger member" (’223 Patent, col. 2:40-42).
  • Evidence for a Narrower Interpretation: The detailed description and figures show a specific embodiment where a "rear surface 74 of the hammer 18" contacts a "contact surface 30 of the trigger member 26" to force the pivot (’223 Patent, col. 5:35-39; Fig. 5). A party might argue the term should be limited to this direct mechanical interaction.

The Term: "locking bar" / "locking member" (from ’223 Claim 4; ’003 Claim 4)

• Context and Importance: This safety feature prevents the firearm from firing out of battery. The infringement analysis will depend on whether the corresponding part in the accused device operates in the manner defined by the claim, specifically its interaction with the bolt carrier.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim describes the component functionally as a "locking bar" that "mechanically blocks the trigger member" and is moved to a non-blocking position "when contacted by the bolt carrier" (’223 Patent, col. 6:42-53).
  • Evidence for a Narrower Interpretation: The specification illustrates a specific pivotally mounted bar (62) whose upper end is displaced by an "engagement surface 54" on the "tail portion 56 of the bolt carrier body 58" (’223 Patent, col. 4:61-68, col. 5:55-58). An argument could be made that the term should be construed to require this specific type of pivotal member and contact point.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement. For inducement, it cites instructional materials, including videos and installation steps, provided on Defendants' website, which allegedly instruct customers on how to use the Accused Product in an infringing manner (Compl. ¶¶ 52, 66). For contributory infringement, it alleges the components of the Disruptor "are not suitable for substantial noninfringing use" and are specially designed to be used in an infringing fire control unit (Compl. ¶¶ 54, 68).

Willful Infringement

• The complaint alleges willful infringement based on pre-suit knowledge of the Asserted Patents. The basis for this allegation includes a page on Defendants' website titled "FRT Legal Library" that allegedly links to copies of the ’223, ’003, and ’336 patents (Compl. ¶33). The complaint also quotes numerous forum posts attributed to the Defendants in which they allegedly discuss Plaintiffs, their patents, and prior litigation, and state "We don't believe we've violated any valid patent" (Compl. ¶¶34-35).

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

• A core issue will be one of functional operation: Does the accused "Disruptor" trigger operate in the specific manner required by the claims? In particular, for the ’003 patent family, does its safety selector achieve mode selection by "preventing said disconnector hook from catching said hammer hook," or does it employ a technically distinct mechanism to achieve a similar result?
• A second key question will be one of claim construction: Can the term "forced to the set position," which describes the central feature of the patented invention, be limited to the specific geometry shown in the patent's embodiments, or does its functional language cover the reset mechanism used in the accused product?
• Finally, a significant issue for damages will be willfulness: Given the extensive allegations of Defendants' pre-suit awareness of the patents and Plaintiffs' enforcement activities, the court will have to determine whether Defendants' alleged infringement, if found, was egregious enough to warrant enhanced damages under 35 U.S.C. § 284.