ABC IP LLC v. Le

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Johnne Le, an individual, d/b/a Sko Prints (Arkansas)
  • Plaintiff's Counsel: Wood Herron & Evans LLP; Fish & Richardson P.C.; WHITAKER, CHALK, SWINDLE AND SCHWARTZ, PLLC; Quattlebaum, Grooms & Tull PLLC
• Case Identification: 2:26-cv-02109, W.D. Ark., 07/13/2026
• Venue Allegations: Venue is alleged to be proper as the Defendant resides in the district and has a regular and established place of business there.
• Core Dispute: Plaintiffs allege that Defendant's aftermarket firearm trigger components, marketed as the "Super Safety," infringe five U.S. patents related to "forced reset" trigger mechanisms.
• Technical Context: The technology concerns trigger mechanisms for AR-platform semiautomatic firearms, which are modified to mechanically reset the trigger using the force of the reciprocating bolt carrier, thereby enabling an accelerated rate of fire.
• Key Procedural History: The complaint states that ABC IP, LLC is the owner by assignment of the Asserted Patents and that Rare Breed Triggers, Inc. is the exclusive licensee. No other procedural events, such as prior litigation between the parties or administrative challenges to the patents, are mentioned.

Case Timeline

Date	Event
2021-11-05	U.S. Patent No. 12,031,784 Priority Date
2022-01-10	U.S. Patent No. 12,636,403 Priority Date
2022-09-08	U.S. Patent No. 12,038,247 Priority Date
2022-09-08	U.S. Patent No. 12,578,159 Priority Date
2023-12-04	U.S. Patent No. 12,529,538 Priority Date
2024-07-09	U.S. Patent No. 12,031,784 Issued
2024-07-16	U.S. Patent No. 12,038,247 Issued
2026-01-20	U.S. Patent No. 12,529,538 Issued
2026-03-17	U.S. Patent No. 12,578,159 Issued
2026-05-26	U.S. Patent No. 12,636,403 Issued
2026-07-13	Complaint Filing Date

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

U.S. Patent No. 12,038,247 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,038,247, "Firearm Trigger Mechanism," issued July 16, 2024 Compl. ¶9

The Invention Explained

• Problem Addressed: The patent addresses the desire among some shooters to increase the rate of fire of a semiautomatic firearm, which is normally limited by the need to manually release and reset the trigger between shots ( Compl. ¶18; Compl. ¶19, Compl. ¶¶col. 1:41-54). Standard mechanisms use a disconnector to prevent the hammer from "following" the bolt, which ensures only one shot is fired per trigger pull Compl. ¶19
• The Patented Solution: The invention is a "drop-in" trigger module that provides three selectable modes: safe, standard semiautomatic, and "forced reset" semiautomatic '247 Patent, abstract In the "forced reset" mode, the rearward movement of the bolt carrier pivots a cam, which in turn mechanically forces the trigger member back to its reset position '247 Patent, abstract '247 Patent, col. 2:55-3:11 This eliminates the need for the user to manually release the trigger, allowing for more rapid subsequent firing '247 Patent, abstract
• Technical Importance: The invention provides a modular, retrofittable unit that allows a user to select between a standard rate of fire and an accelerated, mechanically assisted rate of fire in widely-used firearm platforms '247 Patent, col. 2:20-29

Key Claims at a Glance

• The complaint asserts independent claim 15 Compl. ¶31
• The essential elements of claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, a cam, and a safety selector.
  • The mechanism is operable in a "standard semi-automatic mode" where the user must manually release the trigger to reset the disconnector.
  • The mechanism is also operable in a "forced reset semi-automatic mode" where rearward movement of the bolt carrier causes the cam to force the trigger member to its set position, while the safety selector prevents the disconnector from catching the hammer, allowing the user to fire again without a manual trigger release.
• The complaint reserves the right to assert other claims Compl. ¶31

U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger"

• Patent Identification: U.S. Patent No. 12,031,784, "Adapted Forced Reset Trigger," issued July 9, 2024 Compl. ¶10

The Invention Explained

• Problem Addressed: The patent notes that prior art "forced reset" triggers designed for one firearm pattern (e.g., AR-15) are often not dimensionally compatible with others (e.g., AR-10) '784 Patent, col. 1:20-32 Specifically, a simple extension of the trigger's locking member to engage the differently-positioned bolt carrier of an AR-10 would interfere with the forward portion of that same bolt carrier as it cycles rearward '784 Patent, col. 1:36-44
• The Patented Solution: The invention is a trigger locking member with an "upwardly extending deflectable portion." '784 Patent, col. 6:4-10 This extension is designed to fold, pivot, or otherwise give way when struck by the forward part of the bolt carrier during its rearward travel, but remain rigid enough to be actuated by the rear of the bolt carrier during its forward travel into battery '784 Patent, abstract '784 Patent, col. 2:45-53
• Technical Importance: This design allows the "forced reset" trigger concept to be adapted for use across multiple firearm platforms with varying internal geometries, overcoming the limitations of a fixed-shape locking member '784 Patent, col. 1:5-11

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶45
• The essential elements of claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • A locking member movable between a first (locked) and second (unlocked) position, actuated by contact with a bolt carrier.
  • The locking member has a body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position."
• The complaint reserves the right to assert other claims Compl. ¶45

U.S. Patent No. 12,529,538 - "Safety Mechanism for Firearm"

• Patent Identification: U.S. Patent No. 12,529,538, "Safety Mechanism for Firearm," issued January 20, 2026 Compl. ¶11
• Technology Synopsis: This patent details a safety mechanism that includes a cam selector, a lever, and a trigger with a specific "trigger tail portion." The cam selector has multiple recesses and is configured to operate in three modes: a standard mode where the trigger tail moves freely, an "active reset" mode where the cam forces the trigger tail down to reset the trigger, and a safe mode that prevents the trigger from being pulled '538 Patent, abstract Compl. ¶23
• Asserted Claims: Independent claim 1 is asserted Compl. ¶59
• Accused Features: The "Super Safety" product is alleged to be a safety mechanism comprising the claimed cam selector, lever, and trigger, and to operate in the three claimed modes Compl. ¶61

U.S. Patent No. 12,578,159 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism," issued March 17, 2026 Compl. ¶12
• Technology Synopsis: The patent describes a trigger mechanism operable in a standard semi-automatic mode and a "forced reset" semi-automatic mode. The mechanism uses a cam actuated by the bolt means to force the trigger to reset. In the standard mode, the disconnector catches the hammer, requiring a manual trigger release; in the forced reset mode, the disconnector is prevented from catching the hammer, allowing immediate re-pulling of the trigger '159 Patent, abstract Compl. ¶¶20-21
• Asserted Claims: Independent claim 1 is asserted Compl. ¶73
• Accused Features: The "Super Safety" is alleged to be a trigger mechanism that operates in both the standard and "forced reset" modes as claimed Compl. ¶75

U.S. Patent No. 12,636,403 - "Firearm Trigger Mechanism"

• Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism," issued May 26, 2026 Compl. ¶13
• Technology Synopsis: This patent claims a trigger mechanism with a safety selector that is movable between a "standard semi-automatic position" and a "forced reset semi-automatic position." In the standard position, rearward pressure on the trigger must be reduced to fire again. In the forced reset position, the trigger is mechanically reset, and the user can fire again without reducing trigger pressure '403 Patent, claim 38 Compl. ¶24
• Asserted Claims: Independent claim 38 is asserted Compl. ¶87
• Accused Features: The "Super Safety" is alleged to incorporate a safety selector that allows the user to switch between a standard disconnector mode and a "forced reset" mode Compl. ¶29 Compl. ¶89

III. The Accused Instrumentality

Product Identification

• The accused product is the "(3-Position) 'Super Safety'" Compl. ¶26

Functionality and Market Context

• The "Super Safety" is an aftermarket fire control component for AR-pattern firearms, sold by Defendant via the website "skoprints.com" Compl. ¶27 The complaint alleges it is sold in various configurations, including as a "partial kit" of core components, a "complete kit" with additional standard parts, or "preinstalled in a receiver and/or complete firearm" Compl. ¶27 Functionally, the device is alleged to provide the user with the ability to switch between a standard semiautomatic firing mode that uses a disconnector and a "forced reset" semiautomatic mode where a cam mechanically resets the trigger Compl. ¶29 The complaint includes a screenshot from the Defendant's website showing the "!Super Safety" product for sale Compl. ¶28, p. 7

IV. Analysis of Infringement Allegations

12,038,247 Infringement Allegations

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A firearm trigger mechanism comprising:	When installed and used as directed, the Super Safety is part of a trigger mechanism and functions as a cam that in at least one mode, both causes the reset of the trigger and locks the trigger during the cycle of operation.	¶33	col. 9:23-53
a hammer having a sear catch and a hook for engaging a disconnector and adapted to be mounted in a fire control mechanism pocket of a receiver	The Super Safety is installed with a hammer (red) that has a sear catch and a hook for engaging a disconnector (orange).	¶33	col. 7:47-54
to pivot on a transverse hammer pivot axis between set and released positions, said hammer adapted to be pivoted rearward by rearward movement of a bolt carrier,	The hammer (red) pivots on a transverse hammer pivot axis and is adapted to be pivoted rearward by the bolt carrier.	¶33	col. 7:47-54
a trigger member having a sear and adapted to be mounted in the fire control mechanism pocket to pivot on a transverse trigger member pivot axis between set and released positions,	The Super Safety is installed with a trigger member (brown) that has a sear and pivots on a transverse trigger member pivot axis.	¶33	col. 7:55-61
wherein said sear and sear catch are in engagement in said set positions of said hammer and trigger member and are out of engagement in said released positions of said hammer and trigger member,	The sear of the trigger member (brown) and sear catch of the hammer (red) are in engagement in the set position and out of engagement in the released position.	¶33	col. 7:62-67
said disconnector having a hook for engaging said hammer and adapted to be mounted in the fire control mechanism pocket to pivot on a transverse disconnector pivot axis,	The disconnector (orange) is adapted to be mounted in the fire control mechanism pocket to pivot on a transverse disconnector pivot axis and has a hook for engaging the hammer (red).	¶33	col. 8:31-36
and a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket,	The Super Safety has a cam with a cam lobe and lever that is adapted to be movably mounted in the fire control mechanism pocket.	¶33	col. 8:5-13
whereupon in a standard semi-automatic mode, ... a user must manually release said trigger member to free said hammer from said disconnector to permit said hammer and trigger member to pivot to said set positions so that the user can pull said trigger member to fire the firearm,	In the standard semi-automatic mode, rearward movement of the bolt carrier causes the disconnector hook to catch the hammer hook, requiring the user to manually release the trigger member to free the hammer.	¶33	col. 9:43-56
and whereupon in a forced reset semi-automatic mode, ... rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook, ... at which time the user can pull said trigger member to fire the firearm.	In the "forced reset" semi-automatic mode, the cam mechanically moves the trigger toward the set position, and rearward movement of the bolt carrier causes rearward pivoting of the hammer such that the disconnector hook is prevented from catching the hammer hook, allowing the user to then fire the firearm.	¶33	col. 10:1-12

12,031,784 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
In a forced rest trigger mechanism, an extended trigger member locking device, comprising: a locking member that is movable between a first position in which it locks a trigger against pulling movement	The Super Safety operates as a locking member and has a first position in which it locks the trigger member against pulling movement.	¶47	col. 5:14-22
and a second position where it does not restrict movement of the trigger member,	The Super Safety is moveable to a second position where it does not restrict movement of the trigger member.	¶47	col. 5:14-22
the locking member configured to be movably supported by a frame and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier,	The Super Safety is movably supported by the firearm's lower receiver (frame) and has an upward extending portion configured to make actuating contact with the bolt carrier.	¶47	col. 5:23-29
such actuating contact causing the locking member to move from the first position to the second position,	The actuating contact causes the locking member to move from the first to the second position.	¶47	col. 6:1-3
the locking member having a body portion that is movably supported and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position.	The Super Safety has a movably supported body portion and an upwardly extending deflectable portion (lever arm) with a dovetail connection alleged to allow separate movement relative to the body portion. The complaint provides a rendering to show the accused Super Safety's 'upwardly extending deflectable portion' in both an extended (red) and deflected (green) position, illustrating its separate movement relative to the body Compl. ¶47, p. 27	¶47	col. 6:4-10

Identified Points of Contention

• Scope Questions: For the '784 patent, a primary point of contention may be whether the accused "Super Safety" lever, which allegedly uses a dovetail joint to pivot relative to its body, meets the claim limitation of a "deflectable portion that is separately movable." The analysis may turn on whether "deflectable" is construed to mean only material flexing or if it can also encompass a hinged or pivoting mechanical structure.
• Technical Questions: For the '247 patent, a key question will be evidentiary: what proof demonstrates that in the "forced reset" mode, the accused device's safety selector actively "prevent[s] the disconnector hook from catching said hammer hook" as required by the claim? The specific interaction between the selector and the disconnector will be critical to the infringement analysis. The complaint uses plaintiff-generated renderings to illustrate this interaction, such as one showing the accused "Super Safety" components installed in a fire control pocket Compl. ¶33, p. 10

V. Key Claim Terms for Construction

• The Term: "deflectable portion that is separately movable" (from '784 Patent, claim 1)

• Context and Importance: This term is central to the infringement analysis of the '784 patent, which was designed to adapt a forced-reset mechanism for firearms with different geometries. Practitioners may focus on this term because the defendant could argue its product, which allegedly uses a pivoting dovetail joint Compl. ¶47, p. 26, does not have a "deflectable" portion in the sense of a resilient material bending, but rather a hinged mechanical part.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests a broader meaning by using "deflects or folds" interchangeably and describing a "hinging structure" '784 Patent, col. 2:49-50 '784 Patent, col. 3:26 The abstract also describes the portion as "separately movable," which supports an interpretation including distinct moving parts rather than just material flexion.
  • Evidence for a Narrower Interpretation: The specification also discloses that the extension portion "could be made from a resilient material configured to deflectably bend" '784 Patent, col. 4:45-49 A defendant might cite this language to argue that "deflectable" should be construed more narrowly to mean bending of a single, resilient component, not the pivoting of a multi-part assembly.

• The Term: "preventing said disconnector hook from catching said hammer hook" (from '247 Patent, claim 15)

• Context and Importance: This functional language defines the key difference between the "standard" and "forced reset" modes in the '247 patent. The case may hinge on how this "prevention" is achieved in the accused device versus how it is described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is purely functional, suggesting that any mechanism that achieves the result of preventing the hook from catching could fall within the claim's scope, regardless of the specific mechanical interaction.
  • Evidence for a Narrower Interpretation: The detailed description of the '247 patent explains this function by disclosing that the "safety selector can have a protuberance thereon which, when the safety selector is in the forced reset semi-automatic position, contacts the disconnector preventing" it from catching the hook '247 Patent, col. 3:12-16 A party could argue that this specific embodiment limits the term "preventing" to a direct physical blocking action by a feature on the safety selector.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating the Defendant provides instructions and encourages the use of the "Super Safety" in an infringing manner Compl. ¶34 Compl. ¶48 Contributory infringement is alleged on the basis that the components of the "Super Safety," such as the cam, are "specially designed" for infringing use and are not suitable for "substantial noninfringing use" Compl. ¶36 Compl. ¶50
• Willful Infringement: Willfulness is alleged based on the assertion that the Defendant "has known or should have known" that its actions constituted infringement and that the patents are valid Compl. ¶37 Compl. ¶51 The complaint characterizes the alleged infringement as "egregious" and claims the Defendant could not have had a reasonable belief of non-infringement or invalidity Compl. ¶37 Compl. ¶51

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

1. Claim Construction and Scope: A core issue will be one of definitional scope, particularly for the '784 patent. Can the term "deflectable portion," which is taught in the context of overcoming geometric interference, be construed to cover the accused product's pivoting dovetail joint, or is its meaning limited to the flexing of a resilient material?
2. Mechanism of Infringement: A central evidentiary question will concern the precise operation of the accused "Super Safety." Does the device's safety selector physically interact with the disconnector to "prevent" it from catching the hammer in the forced reset mode, as described in the '247 patent's specification, or does it achieve this outcome through a different, unclaimed mechanism?
3. Patentability Over Prior Art: The patents-in-suit relate to incremental improvements in the crowded field of firearm triggers. The case will likely involve significant challenges to the validity of the asserted claims based on obviousness, focusing on whether the claimed combinations of selectable modes, cams, and disconnector interactions represented a non-obvious advance over prior art related to accelerated and forced-reset triggers.