ABC IP LLC v. Brandon Hiatt

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Brandon Hiatt, an individual, d/b/a Wick Designs (Florida) and Larry Croft, an individual, d/b/a Wick Designs (Florida)
  • Plaintiff's Counsel: Office of Kevin C. Maxwell
• Case Identification: 2:26-cv-02217, M.D. Fla., 07/21/2026
• Venue Allegations: Venue is alleged to be proper as Defendants reside in the district and have a regular and established place of business within the district.
• Core Dispute: Plaintiffs allege that Defendants' "Kabuto" aftermarket firearm trigger mechanism infringes four patents related to "forced reset" triggers that increase the semi-automatic rate of fire.
• Technical Context: The technology involves mechanical trigger assemblies, primarily for AR-platform firearms, that use the energy from a firearm's cycling action to reset the trigger, enabling a faster rate of fire than is possible with standard semi-automatic triggers.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or other significant procedural events related to the asserted patents.

Case Timeline

Date	Event
2021-11-05	Priority Date for U.S. Patent No. 12,031,784
2022-01-10	Priority Date for U.S. Patent No. 12,636,403
2022-09-08	Priority Date for U.S. Patent Nos. 12,038,247 and 12,578,159
2024-07-09	U.S. Patent No. 12,031,784 Issued
2024-07-16	U.S. Patent No. 12,038,247 Issued
2026-03-17	U.S. Patent No. 12,578,159 Issued
2026-05-26	U.S. Patent No. 12,636,403 Issued
2026-07-21	Complaint Filed

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

U.S. Patent No. 12,038,247 - "Firearm Trigger Mechanism," Issued July 16, 2024

The Invention Explained

• Problem Addressed: Standard semi-automatic trigger mechanisms require a user to manually release and reset the trigger after each shot, which limits the potential rate of fire ( Compl. ¶¶18-19; '247 Patent, col. 1:28-40). While methods like "bump firing" exist to increase fire rate, they are inconsistent, and prior forced reset triggers had other limitations ( Compl. ¶20; '247 Patent, col. 1:41-55).
• The Patented Solution: The invention is a trigger mechanism, selectable via a three-position safety selector, that can operate in either a "standard semi-automatic" mode or a "forced reset semi-automatic" mode ( Compl. ¶21; '247 Patent, abstract). In the forced reset mode, the cycling of the firearm's bolt carrier actuates a cam, which in turn mechanically forces the trigger member back to its reset position, allowing the user to fire again immediately without needing to manually release the trigger ( Compl. ¶20; '247 Patent, col. 2:18-68). The safety selector simultaneously prevents the disconnector from catching the hammer, which is a necessary step to enable the immediate subsequent shot ( Compl. ¶21; '247 Patent, abstract).
• Technical Importance: This design provides a "drop-in" modular solution that allows a user to select between a traditional semi-automatic function and a rapid-fire forced-reset function using the firearm's existing safety selector control ( Compl. ¶21; '247 Patent, col. 2:23-27).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶32).
• The essential elements of independent claim 15 are:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
  • The cam is movable between a first position (for standard mode) and a second position where its lobe forces the trigger member towards its set position (for forced reset mode).
  • In "standard semi-automatic mode," the cam is in the first position; the bolt carrier's rearward movement causes the disconnector to catch the hammer; and the user must manually release the trigger to reset the mechanism for the next shot.
  • In "forced reset semi-automatic mode," the cam is in the second position; the bolt carrier's rearward movement causes the disconnector to be prevented from catching the hammer; and the user can pull the trigger again to fire as soon as the bolt carrier returns to battery.
• The complaint reserves the right to assert other claims (Compl. ¶30).

U.S. Patent No. 12,031,784 - "Adapted Forced Reset Trigger," Issued July 9, 2024

The Invention Explained

• Problem Addressed: Prior art forced reset trigger designs, particularly the locking member that prevents out-of-battery firing, were often designed for a specific firearm platform (e.g., an AR15). Adapting these designs to other platforms with different dimensions (e.g., an AR10) presented geometric challenges; a locking member tall enough to be actuated by the AR10's bolt carrier would interfere with other parts of the carrier as it cycled, rendering the device inoperable ('784 Patent, col. 1:20-44).
• The Patented Solution: The patent describes a trigger locking device with an "upwardly extending deflectable portion that is separately movable" from the main body of the locking member ('784 Patent, abstract; '784 Patent, col. 6:5-9). This extension is long enough to be actuated by the bolt carrier when it returns to battery, but it can also independently pivot or "fold" out of the way to allow the forward portion of the cycling bolt carrier to pass without interference ('784 Patent, col. 4:27-38).
• Technical Importance: This innovation allows a forced reset trigger locking mechanism to be adapted for use in multiple firearm platforms with varying geometries, overcoming the limitations of a fixed-shape locking bar ('784 Patent, col. 2:1-10).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶46).
• The essential elements of independent claim 1 are:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • A locking member movable between a first (locked) and second (unlocked) position, supported by a frame.
  • The locking member has an upward extension to make contact with the bolt carrier, causing the member to move from the locked to the unlocked position.
  • The locking member comprises two key parts: a movably supported "body portion" and an "upwardly extending deflectable portion."
  • Crucially, the "deflectable portion" is "separately movable relative to the body portion" between an extended and a deflected position.
• The complaint reserves the right to assert other claims (Compl. ¶44).

U.S. Patent No. 12,578,159 - "Firearm Trigger Mechanism," Issued March 17, 2026

• Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism," Issued March 17, 2026 (Compl. ¶12).
• Technology Synopsis: This patent is related to the '247 Patent and describes a trigger mechanism operable in two modes: a standard semi-automatic mode and a "forced reset" semi-automatic mode (Compl. ¶60). The invention centers on the interaction between a cam, hammer, trigger, and disconnector to achieve the forced reset function, where the cycling of the bolt means mechanically returns the trigger to a set position (Compl. ¶60; '159 Patent, abstract).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶60).
• Accused Features: The complaint alleges the Kabuto device's dual-mode operation, which uses a bolt carrier assembly and a cam to provide a standard mode and a "forced reset" mode, infringes the '159 Patent (Compl. ¶60).

U.S. Patent No. 12,636,403 - "Firearm Trigger Mechanism," Issued May 26, 2026

• Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism," Issued May 26, 2026 (Compl. ¶13).
• Technology Synopsis: This patent, similar to the '247 and '159 patents, describes a trigger mechanism with selectable standard and "forced reset" semi-automatic modes (Compl. ¶23). The invention focuses on the use of a safety selector to choose between the modes, where in the forced reset mode, the selector prevents the disconnector from catching the hammer, thereby enabling a rapid subsequent shot without the user needing to manually release the trigger ('403 Patent, abstract).
• Asserted Claims: Independent claims 38 and 54 are asserted (Compl. ¶¶73-75).
• Accused Features: The complaint accuses the Kabuto device, alleging it uses a safety selector to switch between a standard semi-automatic mode and a "forced reset" semi-automatic mode in a manner that infringes the '403 Patent (Compl. ¶28; Compl. ¶¶74-75).

III. The Accused Instrumentality

Product Identification

The accused product is the "Kabuto" device, an aftermarket firearm trigger mechanism (Compl. ¶25).

Functionality and Market Context

The complaint alleges the Kabuto is a trigger mechanism that defendants make, use, sell, and offer for sale via an Instagram account and a website (Compl. ¶26). The complaint provides an image of the Kabuto device held in a hand (Compl. ¶27). Functionally, the complaint asserts the Kabuto can operate in at least two modes: a "disconnector mode," similar to a standard AR-15 trigger, and a "forced reset" semi-automatic mode (Compl. ¶28). The user allegedly switches between these modes by rotating the firearm's safety selector (Compl. ¶28). The complaint includes plaintiff-generated renderings depicting the accused Kabuto installed in a firearm receiver, illustrating its various components and their alleged interactions (Compl. ¶32).

IV. Analysis of Infringement Allegations

'247 Patent Infringement Allegations

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A firearm trigger mechanism comprising: a hammer having a sear catch and a hook for engaging a disconnector ... adapted to be mounted in a fire control mechanism pocket of a receiver	The Kabuto is installed in a receiver's fire control pocket with a hammer that has a sear catch and a hook for a disconnector.	¶32	col. 7:42-47
a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket,	The Kabuto has a cam with a cam lobe and lever mounted in the fire control mechanism pocket.	¶32	col. 8:4-9
said cam being movable between a first position and a second position, in said second position said cam lobe forces said trigger member towards said set position,	The Kabuto's cam is movable between two positions. In the second position, the cam lobe moves the trigger member toward the set position via a link when in "forced reset" mode.	¶32	col. 8:29-33
whereupon in a standard semi-automatic mode, ... rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook,	In standard mode, rearward movement of the bolt carrier causes the hammer to pivot rearward, and the disconnector hook catches the hammer hook.	¶32	col. 9:11-14
at which time 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 ...	After the disconnector catches the hammer, the user must manually release the trigger to free the hammer from the disconnector, allowing the mechanism to reset.	¶32	col. 9:22-26
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,	In "forced reset" mode, the cam is in its second position. The rearward bolt carrier movement pivots the hammer, but the disconnector hook is prevented from catching the hammer hook.	¶32	col. 9:44-47
and thereafter the bolt carrier moves forward into battery, at which time the user can pull said trigger member to fire the firearm.	After the bolt carrier moves forward, the user can pull the trigger to fire the firearm again without having first manually released it. A plaintiff-generated rendering depicts this state (Compl. ¶32, p. 18).	¶32	col. 9:55-59

Identified Points of Contention

• Scope Questions: The claim requires specific operational sequences for "standard semi-automatic mode" and "forced reset semi-automatic mode." The analysis may focus on whether the accused Kabuto's two modes correspond precisely to the definitions and functions recited in the claim for each respective mode.
• Technical Questions: A key question will be whether the accused mechanism, in its "forced reset" mode, actively "prevent[s]" the disconnector hook from catching the hammer hook as required by the claim. The complaint alleges this occurs, but the evidence and specific mechanical interactions that achieve this prevention will be a central point of technical inquiry.

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a locking member that is movable between a first position in which it locks a trigger against pulling movement and a second position where it does not restrict movement...	The Kabuto operates as a locking member and is movable between a first "locked" position and a second "unlocked" position where it does not restrict trigger movement.	¶46	col. 2:53-58
the locking member is configured to be movably supported by a frame	The Kabuto is movably (pivotally) supported by a frame. A plaintiff-generated rendering shows this pivotal support (Compl. ¶46, p. 23).	¶46	col. 2:58-61
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier,	The Kabuto has an upward extending "lever arm" that is configured to make contact with a surface of the bolt carrier.	¶46	col. 2:61-64
the locking member having a body portion that is movably supported	The Kabuto has a body portion (identified as blue in the complaint's diagrams) that is movably supported by a housing.	¶46	col. 6:3-4
and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position.	The Kabuto has an upward extending "lever arm" (deflectable portion) that is separately movable relative to its body portion. A visual overlay depicts this separate travel (Compl. ¶46, p. 26).	¶46	col. 6:5-9

Identified Points of Contention

• Scope Questions: The infringement analysis will likely center on the claim term "separately movable." The question will be whether the alleged separate movement of the Kabuto's "lever arm" relative to its "body portion" falls within the scope of this term as defined by the patent.
• Technical Questions: Evidence will be required to demonstrate that the accused lever arm is not only "deflectable" but also "separately movable" in the manner claimed. The patent specification describes embodiments with distinct pivot pins allowing this separate motion, raising the question of how the accused device achieves this function and whether it is equivalent.

V. Key Claim Terms for Construction

For the '247 Patent

• The Term: "forced reset semi-automatic mode"
• Context and Importance: This term is central to distinguishing the invention from standard semi-automatic triggers. The definition is critical because infringement requires the accused device to operate in a mode that meets all functional and sequential requirements laid out in the claim for this specific mode, including both the cam action and the prevention of disconnector engagement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The parties may argue that any mode where the bolt's action mechanically resets the trigger qualifies. The title of the patent, "Firearm Trigger Mechanism," is general.
  • Evidence for a Narrower Interpretation: The claim itself provides a detailed, multi-step definition: "...rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook..." ( '247 Patent, cl. 15). The abstract and detailed description further elaborate on the specific interaction between the cam, trigger, and a safety selector that disables the disconnector, suggesting the term is tied to this specific cooperative mechanism ( '247 Patent, abstract; '247 Patent, col. 9:32-47).

For the '784 Patent

• The Term: "upwardly extending deflectable portion that is separately movable relative to the body portion"
• Context and Importance: This term captures the core innovation of the '784 Patent, which aims to solve a geometric interference problem. Practitioners may focus on this term because the case will turn on whether the accused Kabuto's "lever arm" is structurally and functionally the same as this claimed element. The meaning of "separately movable" will be a key point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that "separately movable" encompasses any design where the upper part can move independently of the main body to avoid interference, regardless of the specific mechanism. The claim language itself does not specify a pivot or hinge.
  • Evidence for a Narrower Interpretation: The patent's detailed description and figures explicitly show this portion operating on a distinct pivot pin, describing it as a "foldable extension portion" that "pivots on... a transverse pivot pin 24 relative to the locking bar body 26" ('784 Patent, col. 3:39-43). The abstract also distinguishes between the "movably supported" body portion and the "separately movable" extension portion, suggesting two distinct types of movement are contemplated and enabled by the disclosed structure.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents. The inducement allegations are supported by specific claims that Defendants provide promotional material, such as on their "Wickactual" Instagram account, that instructs customers on how to install and use the accused Kabuto device in a manner that allegedly infringes the patents (Compl. ¶33; Compl. ¶47; Compl. ¶61; Compl. ¶76). A screenshot from this account showing the device being installed in an AR15 is provided as evidence (Compl. ¶33, p. 19). For contributory infringement, the complaint alleges that components of the Kabuto, such as the cam, are specially designed for this infringing use and are not suitable for substantial non-infringing use (Compl. ¶35; Compl. ¶49; Compl. ¶63; Compl. ¶78).
• Willful Infringement: Plaintiffs allege that Defendants' infringement has been and continues to be willful (Compl. ¶31; Compl. ¶45; Compl. ¶59; Compl. ¶73). The complaint asserts that Defendants "have known or should have known" that their actions constituted infringement and could not have had a reasonable belief that the patents were invalid or not infringed, particularly after being served with the complaint (Compl. ¶36; Compl. ¶50; Compl. ¶64; Compl. ¶79).

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

This case presents a focused dispute over aftermarket firearm trigger technology. The outcome will likely depend on the court's resolution of several key technical and legal questions:

1. A central issue will be one of claim construction and scope: For the '784 patent, can the term "separately movable," which is described in the patent's embodiment as a pivoting component, be construed to read on the specific structure and movement of the accused Kabuto's "lever arm"? The degree of structural and functional difference between the claimed invention and the accused device will be paramount.

2. A second question is one of functional mapping: For the patents involving dual-mode operation (e.g., the '247 patent), does the accused Kabuto perform every step of the claimed methods for both "standard" and "forced reset" modes? The infringement analysis will require a detailed, step-by-step comparison of the mechanical interactions between the bolt carrier, cam, selector, and disconnector in both systems.

3. A third question revolves around indirect liability: As the Kabuto is a component part installed by end-users, the strength of the inducement allegations will be critical. The court will need to assess whether the evidence of Defendants' promotional and instructional materials on social media is sufficient to establish the specific intent required to hold them liable for inducing infringement by their customers.