DCT

1:26-cv-00678

ABC IP LLC v. Wojtek LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00678, D.N.H., 08/19/2026
  • Venue Allegations: Venue is alleged to be proper in the District of New Hampshire because Defendants reside in the district and have a regular and established place of business there, and have allegedly committed acts of infringement within the district.
  • Core Dispute: Plaintiffs allege that Defendants' various "forced reset" firearm trigger kits and related products infringe a portfolio of nine U.S. patents directed to firearm trigger mechanisms that mechanically reset after firing.
  • Technical Context: The technology involves trigger mechanisms for semi-automatic firearms that use the reciprocating motion of the firearm's bolt carrier to force the trigger to reset, enabling a faster potential rate of fire than standard trigger designs.
  • Key Procedural History: The complaint states that Plaintiff ABC IP, LLC is the current owner by assignment of the Asserted Patents, with assignments recorded at the USPTO. No other significant procedural events, such as prior litigation between the parties or administrative challenges to the patents, are mentioned.

Case Timeline

Date Event
2017-09-29 Priority Date for '223 Patent
2019-12-24 Issue Date for U.S. Patent No. 10,514,223
2021-11-05 Priority Date for '784 Patent
2022-01-10 Priority Date for '003, '336, '807, and '403 Patents
2022-09-08 Priority Date for '247 and '159 Patents
2023-08-15 Issue Date for U.S. Patent No. 11,724,003
2023-12-04 Priority Date for '538 Patent
2024-07-09 Issue Date for U.S. Patent No. 12,031,784
2024-07-16 Issue Date for U.S. Patent No. 12,038,247
2024-07-16 Issue Date for U.S. Patent No. 12,036,336
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
2026-05-26 Issue Date for U.S. Patent No. 12,636,403
2026-08-19 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. ¶11

The Invention Explained

  • Problem Addressed: The patent background identifies a desire among firearm users to increase the rate of semi-automatic fire. It notes that standard trigger mechanisms are limited by the speed at which a user can manually release and reset the trigger after each shot. Previous solutions to accelerate this process, such as those described in other patents, often required significant modifications to core firearm components like the bolt carrier. Compl. ¶¶25-26 '247 Patent, col. 1:40-2:4
  • The Patented Solution: The invention is a "drop-in" trigger mechanism with a three-position safety selector providing "safe," "standard semi-automatic," and "forced reset semi-automatic" modes. In the "forced reset" mode, the rearward movement of the bolt carrier during the firing cycle causes a cam to pivot, which in turn mechanically forces the trigger member back to its set position. This allows the user to fire another round as soon as the bolt is in battery, without needing to manually release the trigger finger to achieve a reset. '247 Patent, abstract '247 Patent, col. 10:1-26
  • Technical Importance: The technology purports to offer a method for substantially increasing the rate of fire of a semi-automatic firearm through a modular trigger assembly that does not require modification of the firearm's bolt carrier. Compl. ¶28

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 15. Compl. ¶61 The claim chart is presented for Claim 15. Compl. ¶63
  • The elements of Claim 15, as broken down in the complaint, describe a firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam, operable in two modes:
    • A "standard semi-automatic mode" where the disconnector catches the hammer after firing, requiring the user to manually release the trigger to reset the mechanism.
    • A "forced reset semi-automatic mode" where the cam uses the motion of the bolt carrier to mechanically force the trigger to its set position, while the disconnector is prevented from catching the hammer, allowing for immediate subsequent firing. Compl. ¶63, pp. 21-31
  • The complaint reserves the right to assert other claims.

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. ¶12

The Invention Explained

  • Problem Addressed: The patent background explains that prior forced-reset trigger designs, while effective for certain firearm platforms (like the AR-15), are not readily adaptable to others (like the AR-10) due to different internal geometries. Specifically, a locking bar long enough to be actuated by an AR-10's bolt carrier would physically interfere with the front of that same carrier as it cycles rearward, making the mechanism inoperable. '784 Patent, col. 1:21-2:4
  • The Patented Solution: The invention is an extended trigger locking device featuring an "upwardly extending deflectable portion." This portion, which makes contact with the bolt carrier, is designed to be "separately movable" from the main body of the locking member. It is rigid enough to be actuated by the bolt carrier's forward movement but can fold or deflect out of the way during the bolt carrier's rearward movement, thus avoiding interference. '784 Patent, abstract '784 Patent, col. 2:5-9
  • Technical Importance: This design allows a forced-reset trigger mechanism to be compatible with multiple firearm platforms that have differing internal dimensions, without requiring platform-specific components. '784 Patent, col. 1:5-11

Key Claims at a Glance

  • The complaint asserts independent Claim 1. Compl. ¶77
  • Essential elements of Independent 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.
    • The locking member has a "movably supported" body portion and an "upwardly extending deflectable portion."
    • This deflectable portion is "separately movable" relative to the body portion between an "extended position and a deflected position." '784 Patent, claim 1
  • The complaint reserves the right to assert other claims.

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. ¶13
  • Technology Synopsis: The patent describes a safety mechanism employing a "cam selector" with multiple recesses that interacts with a trigger tail. The selector allows for operation in a standard semi-automatic mode, an "active reset" mode where the cam moves the trigger, and a safe mode that prevents the trigger from being pulled. Compl. ¶30
  • Asserted Claims: The complaint asserts at least Claim 1. Compl. ¶93
  • Accused Features: The "Super Safety" is accused of infringing. Compl. ¶93

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. ¶14
  • Technology Synopsis: The patent discloses a device for accelerating a semi-automatic firearm's firing sequence. It uses a cam, rotated by the cycling of the firearm's action, to cause the trigger member to reset and to prevent it from being pulled again until the action is in battery. The device is selectable between a standard semi-automatic mode and a "forced reset" mode. Compl. ¶28
  • Asserted Claims: The complaint asserts at least Claim 1. Compl. ¶107
  • Accused Features: The "Super Safety," "Atrius Selector," and "ARC-Fire" are accused of infringing. Compl. ¶107

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

  • Patent Identification: U.S. Patent No. 10,514,223, "Firearm Trigger Mechanism," issued December 24, 2019. Compl. ¶15
  • Technology Synopsis: The patent describes a device where the cycling of the firearm's action causes hammer contact with the trigger member to mechanically reset both components. A locking bar is included to prevent the trigger from being pulled until the bolt carrier has returned to its in-battery position. Compl. ¶31
  • Asserted Claims: The complaint asserts at least Claim 4. Compl. ¶123
  • Accused Features: "The Disruptor" is accused of infringing. Compl. ¶123

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

  • Patent Identification: U.S. Patent No. 11,724,003, "Firearm Trigger Mechanism," issued August 15, 2023. Compl. ¶16
  • Technology Synopsis: This patent describes a device similar to the '223 Patent but adds a selectable-mode feature, allowing operation in either a standard disconnector semi-automatic mode or a "forced reset" semi-automatic mode. Compl. ¶32
  • Asserted Claims: The complaint asserts at least Claim 4. Compl. ¶137
  • Accused Features: "The Disruptor" is accused of infringing. Compl. ¶137

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

  • Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," issued July 16, 2024. Compl. ¶17
  • Technology Synopsis: This patent describes a device similar to the '223 Patent but adds a selectable-mode feature, allowing operation in either a standard disconnector semi-automatic mode or a "forced reset" semi-automatic mode. Compl. ¶32
  • Asserted Claims: The complaint asserts at least Claim 3. Compl. ¶151
  • Accused Features: "The Disruptor" is accused of infringing. Compl. ¶151

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

  • Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," issued April 15, 2025. Compl. ¶18
  • Technology Synopsis: This patent describes a device similar to the '223 Patent but adds a selectable-mode feature, allowing operation in either a standard disconnector semi-automatic mode or a "forced reset" semi-automatic mode. Compl. ¶32
  • Asserted Claims: The complaint asserts at least Claim 1. Compl. ¶165
  • Accused Features: "The Disruptor" is accused of infringing. Compl. ¶165

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. ¶19
  • Technology Synopsis: This patent describes a device similar to the '223 Patent but adds a selectable-mode feature, allowing operation in either a standard disconnector semi-automatic mode or a "forced reset" semi-automatic mode. Compl. ¶32
  • Asserted Claims: The complaint asserts at least Claim 38. Compl. ¶179
  • Accused Features: The "Infringing Devices," which include the Super Safety, Atrius Selector, ARC-Fire, and Disruptor, are accused of infringing. Compl. ¶179

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are aftermarket firearm trigger mechanisms, sold as kits or pre-installed, identified as "The Super Safety," "The Atrius Selector," "The ARC-Fire," and "The Disruptor." Compl. ¶¶34-53

Functionality and Market Context

The complaint alleges these products are sold as "forced-reset-trigger-kits" on the Defendants' website. Compl. ¶36 The core accused functionality is a selectable trigger system that can operate in a standard semi-automatic mode or a "forced reset" mode. Compl. ¶38 Compl. ¶42 Compl. ¶46 Compl. ¶50 In the "forced reset" mode, the mechanism allegedly uses the motion of the firearm's bolt carrier to interact with a cam, which in turn mechanically resets the trigger, allowing for a faster rate of fire. Compl. ¶51 A product image from Defendants' website shows the "GMR" version of the "Super Safety" kit. Compl. p. 9 The complaint presents these products as direct competitors to Plaintiffs' own "FRT" (Forced Reset Trigger) line of products. Compl. ¶¶54-59

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,038,247 Infringement Allegations

Claim Element (from Independent Claim 1, asserted as part of Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
a firearm trigger mechanism comprising: The Super Safety, Atrius Selector, and ARC-Fire are alleged to be trigger mechanisms that are installed and used as directed. ¶63; ¶64; ¶65 col. 1:19-21
a hammer having a sear catch and a hook for engaging a disconnector... The accused products are installed with a hammer (depicted in red) that has a sear catch and a hook for engaging a disconnector. ¶63 col. 9:25-32
a trigger member having a sear...to pivot...between set and released positions, The accused products are installed with a trigger member (depicted in brown) that has a sear and pivots between set and released positions. ¶63 col. 9:33-40
a disconnector having a hook for engaging said hammer...to pivot... The accused products use a disconnector (depicted in orange) with a hook adapted to engage the hammer. ¶63 col. 9:55-60
a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, The accused products include a cam with a cam lobe (depicted in yellow) that is movably mounted in the fire control mechanism. ¶63 col. 9:61-64
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 cam is movable between two positions; in the second ("forced reset") position, the cam lobe mechanically moves the trigger member toward its set position. ¶63 col. 10:1-10
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... In standard semi-automatic mode, the cam is in its first position, and rearward bolt carrier movement causes the disconnector hook to catch the hammer hook. ¶63 col. 8:11-23
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 once the bolt is in battery. A plaintiff-generated diagram shows the cam and lobe in this second position. Compl. p. 27 ¶63 col. 8:24-42

U.S. Patent No. 12,031,784 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 accused Super Safety is part of a forced reset trigger mechanism and functions as an extended trigger member locking device. ¶79 col. 2:5-9
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 operates as a locking member and is movable between a locked first position and an unlocked second position. ¶79 col. 3:9-14
the locking member...including a generally upward extension portion configured to make actuating contact with a surface of a bolt carrier... The Super Safety has an upward extending portion (lever arm) configured to make actuating contact with a surface of the bolt carrier. ¶79 col. 3:15-18
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 allegedly has a body portion and an upwardly extending deflectable portion (lever arm). The complaint alleges a dovetail joint allows for separate movement of the lever arm relative to the body portion. ¶79 col. 3:40-45

Identified Points of Contention

  • For the '247 Patent: The infringement allegations rely heavily on multi-step functional limitations describing the device's operation in two different modes. A central point of contention may be whether the accused devices operate in the precise sequence claimed. For example, the claim requires that in "forced reset" mode, the cam action "prevents" the disconnector hook from catching the hammer hook. The evidence required to prove this specific negative limitation during the high-speed firing cycle may be a key battleground.
  • For the '784 Patent: The core dispute will likely concern the claim term "separately movable." The patent's embodiment shows a distinct, pinned "foldable extension." The complaint alleges infringement via a "dovetail joint" in the accused Super Safety. Compl. p. 60 This raises the question of whether a dovetail joint, which allows for some play or pivoting before engagement, renders a portion of a component "separately movable" from the body, or if the term requires two distinct, articulated components.

V. Key Claim Terms for Construction

U.S. Patent No. 12,038,247

  • The Term: "forces said trigger member towards said set position"
  • Context and Importance: This term is critical because it defines the core "forced reset" action. The nature and directness of the "force" applied by the cam to the trigger will be central to the infringement analysis. Practitioners may focus on this term to determine if any incidental contact is sufficient, or if a specific type of positive, mechanical displacement is required by the claim.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the interaction in general terms, stating that "pivoting travel of the hammer 36 surface 51 contacts surface 58 of trigger member 38 forcing trigger member 38 to pivot." '247 Patent, col. 10:15-19 This general language could support a reading where various forms of contact that result in the trigger's movement are covered.
  • Evidence for a Narrower Interpretation: The figures, such as FIG. 9C, illustrate a specific geometry where the hammer's concave surface (51) acts on the trigger's convex surface (58) to cause the reset. A defendant may argue that the term "forces" should be limited to the specific type of direct, surface-to-surface interaction shown in the patent's preferred embodiment.

U.S. Patent No. 12,031,784

  • The Term: "separately movable"
  • Context and Importance: This term distinguishes the invention from prior art and is the focal point of the infringement allegation against the accused "dovetail joint" design. The case may turn on whether "separately movable" is construed to mean only a distinct, hinged component or if it can also cover a single component with an integrated joint that allows for relative motion.
  • Intrinsic Evidence for a Broader Interpretation: The summary of the invention states the locking member has an extension that is "separately movable relative to the body portion." '784 Patent, col. 2:6-8 The patent also uses the more general phrase "deflect or fold" to describe the action, which may suggest that means other than a simple hinge are contemplated. '784 Patent, col. 2:7
  • Evidence for a Narrower Interpretation: The primary embodiment explicitly shows the "foldable extension portion 22" pivoting on a "transverse pivot pin 24" relative to the "locking bar body 26." '784 Patent, col. 3:40-45 A defendant may argue that "separately movable" should be limited to this disclosed arrangement of distinct, pinned components, rather than a single integrated part with a flexible joint.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. For inducement, it is alleged that Defendants encourage and instruct customers on how to install and use the accused products in an infringing manner through advertising and other materials. Compl. ¶¶66 Compl. ¶82 For contributory infringement, it is alleged that the components of the accused kits are specially designed for infringing use and are not suitable for substantial non-infringing use. Compl. ¶¶68 Compl. ¶84
  • Willful Infringement: Willfulness is alleged for all asserted patents. The complaint claims Defendants knew or should have known that their actions constituted infringement and could not have formed a reasonable belief that their actions were non-infringing or that the patents were invalid, suggesting post-suit and potentially pre-suit knowledge. Compl. ¶¶69 Compl. ¶85

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

  1. A central issue will be one of definitional scope: For the '784 patent, can the term "separately movable," which is embodied in the patent as a distinct, pinned component, be construed to cover the "dovetail joint" design allegedly used in Defendants' products? This claim construction battle will be critical to determining infringement of this patent.
  2. A key question will be one of operational equivalence: For the '247 patent and its relatives, does the complex, multi-mode operation of the accused products map directly onto the specific functional sequences laid out in the claims? The dispute will likely involve a granular, evidence-intensive comparison of how the claimed invention and the accused devices function during each step of the high-speed firing cycle.
  3. An overarching case management question will be one of technological differentiation: With nine patents asserted across four different product families, the litigation will need to resolve whether the infringement theories are broadly applicable or if the subtle technical differences between each accused product and each asserted patent will necessitate distinct, parallel analyses for each combination.
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