Rare Breed Triggers Inc v. Advanced Threat Assessment Training Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Advanced Threat Assessment and Training Inc., d/b/a War Hammer Armaments (Florida)
  • Plaintiff's Counsel: Contarino Roth LLC
• Case Identification: 2:26-cv-14198, S.D. Fla., 06/05/2026
• Venue Allegations: Venue is alleged to be proper in the Southern District of Florida because the Defendant resides in the district, maintains a regular and established place of business there, and has allegedly committed acts of infringement within the district.
• Core Dispute: Plaintiffs allege that Defendant's "Super Safety" and "Partisan Disruptor" firearm trigger mechanisms infringe nine U.S. patents related to forced reset trigger technology, which is designed to increase the rate of fire of semi-automatic firearms.
• Technical Context: The technology at issue involves mechanical trigger assemblies for AR-platform firearms that use the energy from the firearm's cycling action to mechanically reset the trigger, enabling a faster rate of fire than is possible with a standard semi-automatic trigger.
• Key Procedural History: The complaint alleges that on March 25, 2025, Plaintiffs sent a cease and desist letter to the Defendant, providing notice of U.S. Patent No. 12,038,247 and accusing the "Super Safety" product of infringement. This event is a key factual predicate for the willfulness allegation.

Case Timeline

Date	Event
2017-09-29	Earliest Priority Date for U.S. Patent No. 10,514,223
2019-12-24	U.S. Patent No. 10,514,223 Issued
2021-11-05	Earliest Priority Date for U.S. Patent No. 12,031,784
2022-01-10	Earliest Priority Date for U.S. Patent Nos. 11,724,003; 12,036,336; 12,274,807; 12,636,403
2022-09-08	Earliest Priority Date for U.S. Patent Nos. 12,038,247; 12,578,159
2023-08-15	U.S. Patent No. 11,724,003 Issued
2023-12-04	Earliest Priority Date for U.S. Patent No. 12,529,538
2024-07-09	U.S. Patent No. 12,031,784 Issued
2024-07-16	U.S. Patent No. 12,038,247 Issued
2024-07-16	U.S. Patent No. 12,036,336 Issued
2025-03-25	Cease and Desist Letter Delivered to Defendant
2025-04-15	U.S. Patent No. 12,274,807 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
2026-06-05	Complaint Filing Date

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: In a standard semi-automatic firearm, the rate of fire is limited by the time it takes for a user to manually release the trigger to reset the internal mechanism (the sear and disconnector) before pulling it again Compl. ¶24 The disconnector in a standard design prevents the hammer from following the bolt carrier, which would otherwise result in an uncocked hammer or uncontrolled fire Compl. ¶24
• The Patented Solution: The invention is a trigger mechanism with a selectable "forced reset" mode Compl. ¶26 In this mode, a cam mechanism, which is actuated by the rearward movement of the firearm's bolt carrier, physically forces the trigger member back to its set position Compl. ¶26 This allows the user to fire another round as soon as the action is in battery, without needing to manually release the trigger, thereby accelerating the potential rate of fire '247 Patent, abstract The patent describes a "three position" safety selector that allows the user to choose between safe, standard semi-automatic, and forced reset semi-automatic modes '247 Patent, abstract
• Technical Importance: This design provides a method to substantially increase the cyclic rate of a semi-automatic firearm through a purely mechanical "drop-in" solution, distinct from illegal automatic conversions or other rate-increasing technologies like bump stocks Compl. ¶26

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 15 Compl. ¶45
• The essential elements of independent claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
  • The mechanism is operable in a standard semi-automatic mode, where rearward movement of a bolt carrier causes the disconnector to catch the hammer, requiring the user to manually release the trigger to fire again.
  • The mechanism is also operable in a forced reset semi-automatic mode, where the cam is in a second position.
  • In this forced reset mode, rearward movement of the bolt carrier causes the cam to force the trigger member toward its set position while also preventing the disconnector from catching the hammer, allowing the user to fire again without manually releasing the trigger.
• The complaint reserves the right to assert other claims Compl. ¶45

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

• Issued: July 9, 2024.

The Invention Explained

• Problem Addressed: The complaint alleges that this invention solves the "geometric limitations of prior art designs" that prevent certain forced reset triggers from being used in multiple types of semi-automatic firearms Compl. ¶27 Specifically, the geometry of some firearm platforms (like the AR-10) prevents a simple, rigid locking bar from both being actuated by the bolt carrier and avoiding interference with it during its cycle '784 Patent, col. 1:20-44
• The Patented Solution: The patent discloses an "extended trigger member locking device" featuring an upward extension that is "separately movable" from the main body of the locking member '784 Patent, abstract Compl. ¶27 This allows the extension to be actuated by the bolt carrier's forward movement but to "deflect or fold" out of the way as the bolt carrier cycles to the rear, thus avoiding interference '784 Patent, col. 2:1-6 Compl. ¶27
• Technical Importance: This innovation allows forced reset trigger technology to be adapted to a wider array of firearm platforms with varying internal dimensions, beyond the standard AR-15 pattern for which earlier designs were intended '784 Patent, col. 1:20-35

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶59
• The essential elements of independent claim 1 include:
  • An extended trigger member locking device for a forced reset trigger mechanism.
  • The device comprises a locking member movable between a first "locking" position and a second "unrestricted" position.
  • The locking member is supported by a frame and includes a "generally upward extension portion."
  • This extension portion is configured to make "actuating contact" with the bolt carrier, causing the locking member to move from the first to the second position.
• The complaint reserves the right to assert other claims Compl. ¶59

Multi-Patent Capsule Summaries

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

  • Issued: January 20, 2026.
  • Technology Synopsis: The patent discloses a safety mechanism that uses a "cam selector" with multiple recesses to operate in three distinct modes. The interaction between a "first trigger tail portion" and the recesses on the rotating cam selector determines whether the firearm is in a first mode, a second mode (where the trigger tail is moved down by a cam portion), or a third mode (where the trigger is prevented from being pulled) Compl. ¶28
  • Asserted Claims: At least independent claim 1 Compl. ¶73
  • Accused Features: The "Super Safety" product is alleged to infringe Compl. ¶73

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

  • Issued: March 17, 2026.
  • Technology Synopsis: This patent describes a device for accelerating the firing sequence of a semi-automatic firearm. The device is selectable between a standard semi-automatic mode and a forced reset semi-automatic mode, where a cam, rotated by the cycling of the action, forces the trigger member to reset Compl. ¶26
  • Asserted Claims: At least independent claim 1 Compl. ¶87
  • Accused Features: The "Super Safety" product is alleged to infringe Compl. ¶87

• U.S. Patent No. 10,514,223 - Firearm Trigger Mechanism

  • Issued: December 24, 2019.
  • Technology Synopsis: The patent claims a device where the cycling of the firearm's action causes the hammer to make contact with the trigger, which forcefully resets both components. A "locking bar" is used to prevent the user from pulling the trigger again until the bolt carrier has returned to its in-battery position Compl. ¶29
  • Asserted Claims: At least independent claim 4 Compl. ¶73
  • Accused Features: The "Disruptor" product is alleged to infringe Compl. ¶73

• U.S. Patent No. 11,724,003 - Firearm Trigger Mechanism

  • Issued: August 15, 2023.
  • Technology Synopsis: The patent describes a trigger device with two selectable modes of operation: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode Compl. ¶30 It is described as operating similarly to the inventions of the '336, '807, and '403 patents.
  • Asserted Claims: At least independent claim 4 Compl. ¶87
  • Accused Features: The "Disruptor" product is alleged to infringe Compl. ¶87

• U.S. Patent No. 12,036,336 - Firearm Trigger Mechanism

  • Issued: July 16, 2024.
  • Technology Synopsis: The patent describes a trigger device with two selectable modes of operation: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode Compl. ¶30 It is described as operating similarly to the inventions of the '003, '807, and '403 patents.
  • Asserted Claims: At least independent claim 3 Compl. ¶101
  • Accused Features: The "Disruptor" product is alleged to infringe Compl. ¶101

• U.S. Patent No. 12,274,807 - Firearm Trigger Mechanism

  • Issued: April 15, 2025.
  • Technology Synopsis: The patent describes a trigger device with two selectable modes of operation: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode Compl. ¶30 It is described as operating similarly to the inventions of the '003, '336, and '403 patents.
  • Asserted Claims: At least independent claim 1 Compl. ¶114
  • Accused Features: The "Disruptor" product is alleged to infringe Compl. ¶114

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

  • Issued: May 26, 2026.
  • Technology Synopsis: The patent describes a trigger device with two selectable modes of operation: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode Compl. ¶30 It is described as operating similarly to the inventions of the '003, '336, and '807 patents.
  • Asserted Claims: At least independent claim 38 Compl. ¶128
  • Accused Features: The "Super Safety" and "Disruptor" products are alleged to infringe Compl. ¶128

III. The Accused Instrumentality

Product Identification

• Defendant's "Super Safety" and "Partisan Disruptor" trigger mechanisms Compl. ¶32

Functionality and Market Context

• The complaint alleges both the Super Safety and the Disruptor are three-position mechanisms for AR-pattern firearms, allowing the user to switch between "safe," "standard semiautomatic with disconnector," and "forced reset semiautomatic" modes Compl. ¶36 Compl. ¶40
• In the forced reset mode, the cycling of the firearm's action is alleged to cause components within the devices to forcefully reset the trigger, enabling a subsequent shot without the user manually releasing pressure on the trigger Compl. ¶41 Compl. ¶43
• The complaint includes a photograph of the Super Safety product, showing its constituent parts Compl. ¶35 It also includes a plaintiff-generated rendering that color-codes the alleged cam, hammer, trigger, and disconnector to illustrate their interaction (Compl. ¶47, p. 11). Similarly, a photograph and plaintiff-generated renderings are provided for the Disruptor product (Compl. ¶39; Compl. ¶75, p. 60).
• Defendant allegedly sells the Super Safety as a partial kit, a complete kit, or pre-installed in a receiver or complete firearm Compl. ¶34 The Disruptor is allegedly sold as a standalone product Compl. ¶38 Both are offered for sale on Defendant's website Compl. ¶34 Compl. ¶38

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:	The Super Safety is alleged to be a forced reset trigger mechanism with a cam that forces the trigger to reset and locks it during the cycle of operation.	¶47	col. 1:25-30
a hammer having a sear catch and a hook for engaging a disconnector...	The Super Safety is installed with a hammer (red) that allegedly has a sear catch and a hook for engaging a disconnector (orange).	¶47	col. 8:24-25
a trigger member having a sear...	The Super Safety is installed with a trigger member (brown) that allegedly has a sear and pivots.	¶47	col. 8:6-11
a disconnector having a hook for engaging said hammer...	The Super Safety includes a disconnector (orange) with a hook that is alleged to engage the hammer (red).	¶47	col. 8:26-27
and a cam having a cam lobe...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 Super Safety allegedly has a cam (yellow) with a cam lobe that is movable. In its second position (forced reset mode), the cam lobe allegedly forces the trigger member (brown) toward the set position.	¶47	col. 8:8-13
whereupon in a standard semi-automatic mode...said disconnector hook catches said hammer hook...a user must manually release said trigger member...	In standard mode, the rearward movement of the bolt carrier allegedly causes the disconnector hook (orange) to catch the hammer hook (red), requiring the user to release the trigger.	¶47	col. 9:15-24
and whereupon in a forced reset semi-automatic mode...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 forced reset mode, the cam is allegedly in its second position, which prevents the disconnector hook from catching the hammer hook, allowing the user to fire again without a manual release.	¶47	col. 9:25-34

• Identified Points of Contention:
  • Technical Questions: The complaint's allegations rely heavily on plaintiff-generated diagrams showing the internal mechanics of the accused Super Safety. A central evidentiary question will be whether these diagrams accurately depict the operation of the defendant's product and if the components function as described to meet each limitation of the claim.
  • Scope Questions: The infringement theory is one of direct mechanical correspondence. A potential point of contention may arise over whether the accused components (e.g., the part labeled a "cam") fall within the scope of the patent's claim terms as they would be construed by a court.

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
In a forced reset trigger mechanism, an extended trigger member locking device, comprising:	The Super Safety is alleged to be part of a forced reset trigger mechanism and to function as an extended trigger member locking device.	¶61	col. 1:15-18
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 Super Safety allegedly operates as a locking member movable between a first (locked) position and a second (unlocked) position.	¶61	col. 1:53-57
the locking member configured to be movably supported by a frame...	The Super Safety is allegedly movably supported by a frame (the firearm's lower receiver).	¶61	col. 1:58-59
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier,	The Super Safety allegedly has an upward extending portion (lever arm) configured to make actuating contact with a surface of the bolt carrier.	¶61	col. 1:59-61
such actuating contact causing the locking member to move from the first position to the second position,	The alleged actuating contact from the bolt carrier causes the locking member to move from the first (locked) to the second (unlocked) position.	¶61	col. 2:1-3

• Identified Points of Contention:
  • Scope Questions: The specification of the '784 patent emphasizes a "deflectable" or "separately movable" extension as a solution to a specific geometric problem in certain firearms '784 Patent, abstract Compl. ¶27 However, the asserted independent claim 1 does not explicitly recite this "deflectable" feature. A critical legal question will be whether the term "locking member" should be construed narrowly to include this feature from the specification, or broadly, as its plain language suggests. The plaintiff-generated infringement diagram appears to show a rigid, single-piece locking member, which may create a focal point for this dispute (Compl. ¶61, p. 24).

V. Key Claim Terms for Construction

• The Term: "cam" (from '247 Patent, Claim 15)

• Context and Importance: This term is the central component alleged to enable the "forced reset" functionality by interacting with the firearm's bolt carrier and trigger member. The definition of "cam" will be critical to determining if the accused Super Safety, which allegedly performs a similar function, infringes. Practitioners may focus on this term because the defendant is likely to argue its corresponding component operates differently or does not meet the structural or functional definition of a "cam" as envisioned by the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states, "A cam 72 is movably mounted to the housing 12" '247 Patent, col. 8:8-9 This general language could support a construction that covers any component movably mounted that performs the claimed function of forcing the trigger to reset.
  • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where "The cam 72 has a cam lobe 78 that interacts with the cam follower 58" and has specific contact surfaces '247 Patent, col. 8:11-13 A defendant may argue that the term "cam" should be limited to a pivoting part with a distinct "lobe" and "follower" interaction, as depicted in the patent's figures.

• The Term: "locking member" (from '784 Patent, Claim 1)

• Context and Importance: The scope of this term is central to the infringement analysis of the '784 patent. While the specification highlights a novel "deflectable" extension as a key feature, the asserted independent claim does not explicitly require it. The dispute will likely center on whether this feature should be read into the claim from the specification.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is broad, requiring only a "locking member that is movable" and has an "upward extension portion" '784 Patent, claim 1 Plaintiffs may argue this plain language should govern and that it reads directly on the accused device as depicted in the complaint.
  • Evidence for a Narrower Interpretation: The patent's abstract describes an "upwardly extending deflectable portion that is separately movable relative to the body portion," and the background section explains this feature solves a problem with prior art designs '784 Patent, abstract '784 Patent, col. 1:40-44 Defendant may argue that these statements constitute a clear disavowal of claim scope, limiting the term "locking member" to only those structures that possess this separately movable or deflectable quality.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. It claims Defendant induces infringement by providing customers with promotional materials and instructions on how to install and use the accused devices in an infringing manner Compl. ¶48 Compl. ¶62 The complaint includes a screenshot of an "AR15 Platform Installation" video from Defendant's website as evidence of this inducement (Compl. ¶48, p.21). The complaint further alleges contributory infringement by asserting that key components of the accused devices, such as the "cam or cam lever arm," are not suitable for substantial non-infringing use and are specially designed to be used in an infringing manner Compl. ¶50 Compl. ¶64
• Willful Infringement: The complaint alleges willful infringement for all asserted patents. The willfulness claim for the '247 patent is supported by the allegation that Defendant had pre-suit knowledge via a cease and desist letter dated March 25, 2025 Compl. ¶22 Compl. ¶51 For all patents, the complaint alleges that Defendant knew or should have known its actions constituted infringement and could not have formed a reasonable, good-faith belief of non-infringement or invalidity Compl. ¶51 Compl. ¶65

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

• A core issue will be one of claim construction and scope: For the '784 patent, the case may turn on whether the term "locking member" is interpreted broadly according to its plain language in the claim, or narrowly to include the "separately movable" or "deflectable" feature heavily emphasized in the patent's specification.

• A key evidentiary question will be one of technical and functional accuracy: Does the real-world operation of the accused "Super Safety" and "Disruptor" products match the functional descriptions and plaintiff-generated diagrams in the complaint, thereby performing the specific, multi-step sequences of a "forced reset" as required by the various asserted claims?

• A central question for damages and liability will be the nature of the infringing sales: The court will need to resolve whether Defendant's sale of the accused products in kit form constitutes direct infringement through its own testing, or if liability stems primarily from indirect infringement (inducement and contributory) based on the actions of its customers, which would require proof of the requisite knowledge and intent.