DCT

3:26-cv-05070

ABC IP LLC v. Gross

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:26-cv-05070, W.D. Mo., 08/05/2026
  • Venue Allegations: Venue is alleged to be proper as Defendant is domiciled in, has committed acts of infringement in, and has a regular and established place of business in the Western District of Missouri.
  • Core Dispute: Plaintiffs allege that Defendant's aftermarket firearm trigger mechanisms, sold under names including "Super Safety," "Kubota," and "Selektor," infringe nine U.S. patents related to "forced reset" trigger technology.
  • Technical Context: The technology at issue involves mechanical trigger systems for semi-automatic firearms, such as the AR-15 platform, that are designed to enable a faster rate of fire than standard trigger mechanisms by using the firearm's cycling action to reset the trigger.
  • Key Procedural History: The complaint asserts nine patents and also includes claims for trademark infringement related to Plaintiffs' "FRT" mark, alleging that Defendant is trading on Plaintiffs' goodwill.

Case Timeline

Date Event
2017-09-29 Priority Date for U.S. Patent No. 10,514,223
2019-12-24 Issue Date for U.S. Patent No. 10,514,223
2020-01-01 Plaintiffs' use of FRT mark commences (stated as "at least 2020")
2021-11-05 Priority Date for U.S. Patent Nos. 12,031,784 and 12,578,159
2022-01-10 Priority Date for U.S. Patent Nos. 11,724,003, 12,036,336, 12,274,807, and 12,636,403
2022-01-31 Application Date for "FRT-15" Trademark
2022-02-01 Application Date for "FRT", "FRT-22", "FRT-47" Trademarks
2022-09-08 Priority Date for U.S. Patent No. 12,038,247
2023-03-21 Registration Date for "FRT-15" Trademark
2023-08-15 Issue Date for U.S. Patent No. 11,724,003
2023-12-04 Priority Date for U.S. Patent No. 12,529,538
2024-07-09 Issue Date for U.S. Patent No. 12,031,784
2024-07-16 Issue Date for U.S. Patent Nos. 12,038,247 and 12,036,336
2024-08-24 Application Date for "FRT-15L3" Trademark
2025-04-15 Issue Date for U.S. Patent No. 12,274,807
2026-01-20 Issue Date for U.S. Patent No. 12,529,538
2026-03-17 Issue Date for U.S. Patent No. 12,578,159
2026-03-20 Application Date for "FRT-MR3" and "FRT-RD3" Trademarks
2026-03-24 Registration Date for "FRT" Trademark
2026-04-21 Registration Date for "FRT-15L3" Trademark
2026-04-28 Registration Date for "FRT-22" and "FRT-47" Trademarks
2026-05-26 Issue Date for U.S. Patent No. 12,636,403
2026-08-05 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 (the "'247 Patent").

The Invention Explained

  • Problem Addressed: The complaint describes that standard semi-automatic triggers, which use a disconnector, fire only one round per pull and require the user to manually reset the trigger, which limits the rate of fire Compl. ¶¶24-25
  • The Patented Solution: The invention is a "forced reset" trigger mechanism that uses the cycling of the firearm's bolt carrier to rotate a cam Compl. ¶27 This cam mechanically forces the trigger member back to its reset position, allowing the user to fire again as soon as the action is in battery without needing a traditional disconnector or requiring the user to manually release and reset the trigger Compl. ¶26 Compl. ¶27 The complaint alleges the device is selectable between a standard semi-automatic mode and a "forced reset" mode Compl. ¶27
  • Technical Importance: This type of mechanism allows a user to achieve a significantly faster rate of semi-automatic fire than is possible with a standard trigger design Compl. ¶27

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶57
  • The essential elements of claim 15 include:
    • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
    • The hammer pivots between set and released positions and is pivoted rearward by the bolt carrier.
    • The trigger member has a sear that engages a sear catch on the hammer in the set position.
    • The cam is movable between a first position (for standard semi-automatic mode) and a second position (for forced reset mode).
    • In the second position, a cam lobe forces the trigger member towards its set position.
    • In the standard mode, the disconnector catches the hammer, and the user must manually release the trigger to fire again.
    • In the forced reset mode, the cam is in the second position, preventing the disconnector from catching the hammer, allowing the user to pull the trigger again without a manual release once the bolt carrier is in battery.
  • The complaint reserves the right to assert other claims Compl. ¶57

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 (the "'784 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section notes that geometric differences between firearm platforms like the AR-15 and the larger-caliber AR-10 prevent a single "drop-in" forced reset trigger design from being universally compatible '784 Patent, col. 1:21-44 Specifically, an extended locking member tall enough for an AR-10's bolt carrier would interfere with the forward part of that same carrier as it cycles rearward ('784 Patent, col. 1:40-44).
  • The Patented Solution: The invention is an extended trigger locking device that features a "deflectable extension" '784 Patent, abstract This extension is designed as a one-way hinge, allowing it to be actuated by the forward movement of the bolt carrier but also to "deflect or fold separately" to avoid interference with the forward portion of the bolt carrier as it cycles to the rear '784 Patent, col. 2:60-64 '784 Patent, FIG. 7
  • Technical Importance: This design allows a forced reset trigger mechanism to be adapted for use in multiple semi-automatic firearm platforms with differing geometries, which was a limitation of prior designs Compl. ¶28

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶72
  • The essential elements of claim 1 include:
    • In a forced reset trigger mechanism, an extended trigger member locking device.
    • The locking member is movable between a locked first position and an unlocked second position.
    • It includes an upward extension portion to make actuating contact with the bolt carrier.
    • The locking member has a movably supported body portion.
    • It also has an "upwardly extending deflectable portion that 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. ¶72

Multi-Patent Capsule: U.S. Patent No. 12,529,538

  • Patent Identification: U.S. Patent No. 12,529,538, "Safety Mechanism for Firearm," issued January 20, 2026 (the "'538 Patent").
  • Technology Synopsis: The patent describes a safety mechanism for a firearm employing a cam selector, a lever, and a trigger Compl. ¶29 The cam selector has multiple recesses and is configured for three modes: a first mode where a trigger tail is movable in a first recess, a second mode where the trigger tail engages a second recess and is moved by a cam portion, and a third mode that prevents the trigger from being pulled '538 Patent, abstract
  • Asserted Claims: Independent claim 1 is asserted Compl. ¶87
  • Accused Features: The "Super Safety" product is accused of infringing the '538 Patent Compl. ¶87

Multi-Patent Capsule: U.S. Patent No. 12,578,159

  • Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism," issued March 17, 2026 (the "'159 Patent").
  • Technology Synopsis: This patent, similar to the '247 Patent, describes a device for accelerating the firing sequence of a semi-automatic firearm Compl. ¶27 The mechanism uses a cam, rotated by the cycling of the action, to cause the trigger member to reset and prevent it from being pulled again until the action has returned to the in-battery position. It can operate in either a standard semi-automatic mode or a "forced reset" semi-automatic mode Compl. ¶27
  • Asserted Claims: Independent claim 1 is asserted Compl. ¶101
  • Accused Features: The "Super Safety" and "Kubota" products are accused of infringing the '159 Patent Compl. ¶101

Multi-Patent Capsule: U.S. Patent No. 10,514,223

  • Patent Identification: U.S. Patent No. 10,514,223, "Firearm Trigger Mechanism," issued December 24, 2019 (the "'223 Patent").
  • Technology Synopsis: This patent discloses a device where the cycling of the firearm's action causes the hammer to contact the trigger member, which mechanically resets both components '223 Patent, abstract A locking bar prevents the trigger from being pulled again until the bolt carrier has returned to its in-battery position Compl. ¶30
  • Asserted Claims: Independent claim 4 is asserted Compl. ¶116
  • Accused Features: The "Selektor" product is accused of infringing the '223 Patent Compl. ¶116

Multi-Patent Capsule: U.S. Patent Nos. 11,724,003; 12,036,336; 12,274,807; and 12,636,403

  • Patent Identification: '003, '336, '807, and '403 Patents.
  • Technology Synopsis: These four patents are described together as claiming a similarly operating "forced reset" device with the additional feature that it can be selected to operate in two distinct modes: a standard disconnector semi-automatic mode and a "forced reset" semi-automatic mode Compl. ¶31
  • Asserted Claims: Claim 4 of the '003 Patent, claim 3 of the '336 Patent, claim 1 of the '807 Patent, and claim 38 of the '403 Patent are asserted Compl. ¶130 Compl. ¶144 Compl. ¶157 Compl. ¶171
  • Accused Features: The "Selektor" is accused of infringing the '003, '336, and '807 Patents Compl. ¶130 Compl. ¶144 Compl. ¶157 The "Super Safety," "Kubota," and "Selektor" (collectively, the "Infringing Devices") are accused of infringing the '403 Patent Compl. ¶171

III. The Accused Instrumentality

Product Identification

  • The complaint identifies three accused product lines: the "Super Safety," the "Kubota," and "the Selektor" (Compl. ¶¶34; Compl. ¶39; Compl. ¶43).

Functionality and Market Context

  • The accused products are aftermarket trigger mechanisms for AR-pattern firearms, sold as kits or standalone products on Defendant's website Compl. ¶¶35-36 Compl. ¶40 Compl. ¶44 The complaint provides a screenshot of the "FAST TRIGGER D2 SET" being sold as a kit Compl. p. 9 All three product lines are alleged to operate with selectable modes, including a standard semi-automatic "disconnector mode" and a "forced reset" mode that uses a cam or similar mechanism to mechanically reset the trigger Compl. ¶38 Compl. ¶42 Compl. ¶46 The complaint alleges these products are advertised and sold using Plaintiffs' "FRT" trademark, which stands for Forced Reset Trigger Compl. ¶¶50-52 A screenshot from Defendant's website shows a search for "FRT" returning an "AK 47 FRT Set" and a buffer described as "Best for FRT" Compl. p. 14

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...a trigger member...a disconnector...and a cam... When installed, the Super Safety and Kubota function as a trigger mechanism with a cam that causes the reset of the trigger and locks it during operation. ¶59; ¶60 *
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 accused cam is movable between positions. In the "forced reset" mode (second position), the cam lobe mechanically moves the trigger member toward the set position. ¶59; ¶60 *
whereupon in a standard semi-automatic mode, said cam is in said first position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook...at which time a user must manually release said trigger member... In standard mode, the cam is in its first position and the disconnector hook catches the hammer hook, requiring the user to manually release the trigger. ¶59; ¶60 *
whereupon in a forced reset semi-automatic mode, said cam is in said second position, 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 forced reset mode, the cam is in its second position, which prevents the disconnector from catching the hammer, allowing the user to fire again without a manual release. ¶59; ¶60 *
Note: The patent document for the '247 Patent was not provided; therefore, patent specification citations could not be verified.

A plaintiff-generated rendering shows the alleged interaction of the Super Safety's components, including the cam (yellow) acting on the trigger member (brown) Compl. p. 21

'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: 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 of the trigger member... The Super Safety and Kubota operate as a locking member with a locked first position and an unlocked second position. ¶74; ¶75 col. 3:9-21
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 body portion and an upwardly extending deflectable "lever arm." A dovetail connection is alleged to allow separate movement of the lever arm relative to the body portion. ¶74 col. 3:50-54

A rendering in the complaint illustrates the alleged "dovetail joint" of the Super Safety, which is designed to allow the lever arm to move separately from the main body of the locking member Compl. p. 45

  • Identified Points of Contention:
    • Scope Questions: A central question for the '784 Patent will be whether the accused products' multi-piece locking members, such as the "dovetail joint" alleged for the Super Safety, meet the claim limitation of "an upwardly extending deflectable portion that is separately movable." A defendant may argue that a hinged or jointed component is not "deflectable."
    • Technical Questions: For the '247 patent, a key question will be whether the accused products' "cam" performs the dual functions of both forcing the trigger reset and preventing the disconnector from catching the hammer, as required by the claim language. The complaint's visual evidence suggests a complex interaction between multiple components that will require expert testimony to resolve Compl. pp. 15-25

V. Key Claim Terms for Construction

  • Term: "upwardly extending deflectable portion that is separately movable relative to the body portion" ('784 Patent, Claim 1)
  • Context and Importance: This term appears to be the primary inventive concept of the '784 Patent, intended to distinguish it from prior art by allowing a locking member to adapt to different firearm geometries Compl. ¶28 The infringement case for this patent will likely depend on whether the accused devices, which allegedly use joints and multi-piece assemblies, fall within the scope of a "deflectable" and "separately movable" portion.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the invention as providing a "one-way hinge feature" that causes the locking member to "deflect or fold" '784 Patent, col. 2:60-64 Plaintiffs may argue that "deflect" and "fold" are broad terms encompassing the hinged or jointed action of the accused products.
    • Evidence for a Narrower Interpretation: The figures in the '784 Patent depict a specific embodiment where an extension piece pivots on a pin relative to the main body '784 Patent, FIGS. 2-4 A defendant may argue that the claims should be limited to this disclosed pivoting structure, rather than the "dovetail joint" alleged in the Super Safety Compl. p. 45

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations of Defendant "encouraging, advertising, promoting, and instructing others to use and/or how to use" the accused products, including through a "Super Safety Guide" Compl. ¶61 Compl. ¶76 Compl. p. 40 Contributory infringement is based on allegations that Defendant sells components, such as the cam or cam lever arm, that are "specially designed" for infringement and are "not suitable for substantial noninfringing use" Compl. ¶63 Compl. ¶78
  • Willful Infringement: Willfulness is alleged for all asserted patents. The complaint claims that Defendant "has known or should have known" that its actions constituted infringement and continued its activities despite the "objectively high likelihood" of infringement Compl. ¶64 Compl. ¶79 This allegation is based on both alleged pre-suit and post-suit knowledge.

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

  • A core issue will be one of claim construction: Can the term "deflectable portion that is separately movable" from the '784 Patent be construed to cover the multi-piece, jointed locking members of the accused products? The answer to this will likely determine the outcome of infringement for at least one of the key patents.
  • A second central question is one of evidence for indirect infringement: Will Plaintiffs be able to prove that the sale of unassembled kits, combined with online instructions and marketing, constitutes induced and contributory infringement? This will focus on the Defendant's knowledge, intent, and whether the sold components have substantial non-infringing uses.
  • Finally, a key case management question will be one of complexity and focus: With nine patents-in-suit covering similar "forced reset" technology, the case will likely turn on how the parties and the court narrow the dispute to a manageable set of representative claims and patents. The significant overlap in the asserted patents' subject matter suggests that claim differentiation and potential invalidity challenges based on double patenting may become important issues.
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