DCT

7:26-cv-04425

ABC IP LLC v. Sker Industries LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-04425, S.D.N.Y., 06/16/2026
  • Venue Allegations: Plaintiffs allege that venue is proper because Defendants reside in or have a regular and established place of business in the Southern District of New York and have committed acts of infringement in the district.
  • Core Dispute: Plaintiffs allege that Defendants' firearm trigger mechanisms and related components 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 firearms like the AR-15, which use the cycling of the firearm's action to mechanically reset the trigger, enabling a faster rate of fire than standard semi-automatic mechanisms.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

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. Patents '003, '336, '807, '403
2022-09-08 Earliest Priority Date for U.S. Patents '247 and '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
2025-04-15 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
2026-06-16 Complaint Filing Date

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

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

The Invention Explained

  • Problem Addressed: Standard semi-automatic triggers require a shooter to manually release the trigger to reset the firing mechanism, which limits the potential rate of fire Compl. ¶¶24-25 This is because a disconnector holds the hammer in a cocked position until the trigger is released, preventing the hammer from "following" the bolt carrier and enabling only a single shot per pull-and-hold of the trigger Compl. ¶25
  • The Patented Solution: The invention is a "forced reset" trigger mechanism that adds a mode of operation to a standard semi-automatic trigger Compl. ¶¶26-27 This mechanism uses a cam that is rotated by the cycling of the firearm's action (i.e., the movement of the bolt carrier) Compl. ¶27 This cam mechanically forces the trigger member back to its reset position, allowing the user to fire again without having to manually release the trigger Compl. ¶27 The '247 patent specifically claims a mechanism operable in both a "standard semi-automatic mode" and a "forced reset semi-automatic mode" Compl. ¶56
  • Technical Importance: This technology allows for a significantly accelerated rate of semi-automatic fire from a standard firearm platform, such as an AR-15, by automating the trigger reset step Compl. ¶27

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 15 Compl. ¶54
  • The essential elements of independent claim 15 include:
    • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam with a cam lobe.
    • The mechanism is operable in a "standard semi-automatic mode" where rearward movement of the 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 the forced reset mode, rearward movement of the bolt carrier causes the cam lobe to force the trigger member towards its set position, while the disconnector is prevented from catching the hammer.
    • This allows the user to pull the trigger again to fire, once the bolt carrier has returned to battery, without first manually releasing the trigger.
  • The complaint reserves the right to assert other claims Compl. ¶54

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

The Invention Explained

  • Problem Addressed: Prior art "forced reset" trigger designs, particularly for the AR-15 platform, have geometric limitations that prevent their use in other firearm designs, such as the AR-10, which has different dimensions between the bolt carrier and the fire control pocket Compl. ¶28 '784 Patent, col. 1:21-3:4 A locking bar designed for an AR-15 would be too short to be actuated by an AR-10 bolt carrier, and extending it would cause it to interfere with the bolt carrier's forward portion during cycling '784 Patent, col. 2:35-44
  • The Patented Solution: The '784 patent discloses an extended trigger member locking device with a "deflectable extension" Compl. ¶28 This extension is "separately movable relative to the body portion" of the locking member '784 Patent, abstract '784 Patent, col. 3:9-12 This design allows the upward extension to be long enough to be actuated by the bolt carrier returning to battery, while also being able to fold or deflect out of the way to avoid interfering with another part of the bolt carrier as it cycles to the rear '784 Patent, col. 3:5-15
  • Technical Importance: This innovation enables the "forced reset" trigger technology to be adapted for use in multiple and varied semi-automatic firearm platforms beyond the standard AR-15 design for which it was originally conceived Compl. ¶28

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 Compl. ¶71
  • The 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) position and a second (unlocked) position.
    • The locking member has an upward extension portion to make "actuating contact" with the 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 and a deflected position.
  • The complaint reserves the right to assert other claims Compl. ¶71

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.
  • Technology Synopsis: The patent describes a safety mechanism for a firearm employing a cam selector with multiple recesses and a lever Compl. ¶29 The mechanism operates in three modes: a first mode (standard semi-automatic), a second "active reset" mode where a cam portion moves the trigger, and a third "safe" mode that prevents the trigger from being pulled '538 Patent, abstract
  • Asserted Claims: Claim 1 Compl. ¶88
  • Accused Features: The "Super Safety" product is alleged to embody this technology Compl. ¶88

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.
  • Technology Synopsis: This patent, along with the '247 patent, provides a device for accelerating a firearm's firing sequence Compl. ¶27 It discloses a mechanism selectable between a standard semi-automatic mode and a "forced reset" mode that uses a cam, rotated by the action's cycling, to reset the trigger member and prevent it from being pulled until the action is in battery '159 Patent, abstract
  • Asserted Claims: Claim 1 Compl. ¶102
  • Accused Features: The "Super Safety," "Atrius Selector Clone," "ARC-Fire," and "Kabuto" products are alleged to infringe Compl. ¶102

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.
  • Technology Synopsis: This patent describes a device where the cycling of the action causes the hammer to contact the trigger member, which mechanically resets both the hammer and trigger Compl. ¶30 A locking bar prevents the trigger from being pulled again until the bolt carrier has returned to the in-battery position '223 Patent, abstract
  • Asserted Claims: Claim 4 Compl. ¶119
  • Accused Features: "The Disruptor" product is alleged to infringe this patent (Compl. ¶¶47; Compl. ¶119).

Multi-Patent Capsule: U.S. Patents '003, '336, '807, and '403

  • Patent Identification: U.S. Patent Nos. 11,724,003 (issued Aug. 15, 2023), 12,036,336 (issued Jul. 16, 2024), 12,274,807 (issued Apr. 15, 2025), and 12,636,403 (issued May 26, 2026).
  • Technology Synopsis: These patents describe and claim a "forced reset" device similar to the '223 patent, with the additional feature of being selectable between two modes: a standard disconnector semi-automatic mode and a "forced reset" semi-automatic mode Compl. ¶31 This dual-mode functionality is controlled by a safety selector '003 Patent, abstract
  • Asserted Claims: Claim 4 of '003 patent Compl. ¶133; claim 3 of '336 patent Compl. ¶147; claim 1 of '807 patent Compl. ¶160; claim 38 of '403 patent Compl. ¶174
  • Accused Features: "The Disruptor" is alleged to infringe the '003, '336, and '807 patents Compl. ¶47 The "Super Safety," "Atrius Selector Clone," "ARC-Fire," "Kabuto," and "Disruptor" (collectively, "the Infringing Devices") are alleged to infringe the '403 patent Compl. ¶174

III. The Accused Instrumentality

Product Identification

  • The accused products are the "Super Safety," "Atrius Selector Clone," "ARC-Fire," "Kabuto," and "The Disruptor" (collectively, "the Infringing Devices") Compl. ¶33

Functionality and Market Context

  • The complaint alleges these are trigger components and assemblies for AR-15 pattern firearms, sold by Defendants via their website and other channels Compl. ¶¶35-36 The core functionality alleged is the ability to operate in at least two modes: a "disconnector mode" similar to a standard semi-automatic trigger, and a "forced reset" mode where a cam mechanism, actuated by the firearm's cycling, mechanically resets the trigger (Compl. ¶¶37; Compl. ¶40; Compl. ¶43; Compl. ¶46; Compl. ¶49). A plaintiff-generated rendering shows the accused "Atrius Selector Clone" product, highlighting its selector switch for different modes Compl. p. 21 The complaint asserts that these devices allow for an accelerated rate of fire Compl. ¶27

IV. Analysis of Infringement Allegations

12,038,247 Patent Infringement Allegations

The '247 patent document was not provided. The patent citations below are derived from U.S. Patent No. 11,724,003, a related family member, and are included for illustrative purposes.

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 ... a trigger member having a sear ... said disconnector having a hook for engaging said hammer... The accused Super Safety is installed with a hammer, trigger member, and disconnector, which are standard components of a fire control mechanism Compl. p. 11 A plaintiff-generated diagram shows these components installed in a receiver Compl. p. 12 ¶56 col. 7:1-25
and a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, The Super Safety product itself is alleged to be a cam with a cam lobe and lever, adapted for mounting in the fire control pocket Compl. p. 15 A diagram shows the standalone Super Safety component, identifying the cam and lobe Compl. p. 15 ¶56 col. 7:26-36
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 Super Safety is alleged to be movable between positions. In the second, "forced reset" position, the cam lobe mechanically moves the trigger member toward its set position Compl. p. 16 ¶56 col. 8:3-11
whereupon in a standard semi-automatic mode, ... rearward movement of the bolt carrier causes ... said disconnector hook catches said hammer hook, ... at which time a user must manually release said trigger member ... to fire the firearm, and In the standard mode (first position), rearward bolt movement causes the disconnector to catch the hammer hook Compl. p. 17 The user must then manually release the trigger to reset the mechanism and fire again Compl. p. 18 ¶56 col. 8:12-25
whereupon in a forced reset semi-automatic mode, ... rearward movement of the bolt carrier causes ... 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 mode (second position), rearward bolt movement pivots the hammer, but the cam prevents the disconnector from catching it Compl. p. 19 This allows the user to pull the trigger to fire again without a manual release Compl. p. 20 ¶56 col. 8:26-44
  • Identified Points of Contention:
    • Scope Questions: A central question may be the construction of "forces said trigger member towards said set position." The analysis will examine whether the interaction between the accused cam and trigger meets the claimed "forcing" limitation, or if its operation is technically different.
    • Technical Questions: The complaint relies heavily on plaintiff-generated diagrams to illustrate the function of the accused products within a firearm assembly. A key question will be whether the actual operation of the accused devices, when installed, matches the functional sequences depicted in these diagrams and required by the claim language for both the "standard" and "forced reset" modes.

12,031,784 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... The accused Atrius Selector Clone is alleged to be an extended trigger member locking device that operates as a locking member, movable between a locked first position and an unlocked second position Compl. p. 60 Compl. p. 61 ¶74 col. 3:5-15
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, The Atrius Selector Clone is alleged to have an upward extending lever arm configured to make actuating contact with a surface of the bolt carrier, which causes the locking member to move from the first to the second position Compl. p. 62 Compl. p. 63 ¶74 col. 3:16-20
the locking member having a body portion that is movably supported The body portion of the accused Atrius Selector Clone is alleged to be movably supported by the lower receiver using a detent Compl. p. 63 ¶74 col. 3:21-23
and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position. The Atrius Selector Clone is alleged to have an upwardly extending "deflectable portion (lever arm)" designed for separate movement relative to its body portion Compl. p. 64 A diagram illustrates the separate travel of this lever arm, showing it in both extended and deflected positions Compl. p. 65 ¶74 col. 3:24-28
  • Identified Points of Contention:
    • Scope Questions: The term "deflectable portion that is separately movable" will be a key point of construction. The dispute will likely center on whether the hinged lever arm of the accused products, as shown in the complaint's diagrams Compl. p. 64, meets the claimed functional and structural requirements of being "separately movable" from the "body portion."
    • Technical Questions: Evidence will be needed to establish that the accused locking member's separate movement is relative to its own "body portion," as claimed, and not just a pivoting of the entire assembly. The complaint's diagrams attempt to show this distinction, but it will be a factual question for the court.

V. Key Claim Terms for Construction

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

  • The Term: "forces said trigger member towards said set position" (from claim 15)
  • Context and Importance: This term is the functional core of the "forced reset" invention. The definition will determine whether the interaction between the accused cam and the trigger constitutes infringement. Practitioners may focus on this term to dispute whether the accused products' operation involves the specific type of mechanical "forcing" envisioned by the patent, as opposed to merely enabling or guiding the trigger's movement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification for the related '223 patent uses language like "contact causing the trigger member to be forced to the set position," which suggests that direct mechanical contact that results in the trigger reaching its set position would meet the limitation '223 Patent, col. 5:36-38
    • Evidence for a Narrower Interpretation: The specific embodiment shown in the figures of the related patents, such as Figure 5 of the '223 patent, illustrates a particular geometry where a rear surface (74) of the hammer contacts a surface (30) of the trigger. A party could argue the term "forces" should be limited to this specific push--based mechanical interaction depicted.

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

  • The Term: "separately movable relative to the body portion" (from claim 1)
  • Context and Importance: This term is critical as it defines the novel feature intended to adapt the forced-reset mechanism to different firearm platforms like the AR-10. The infringement analysis will turn on whether the accused products' hinged or folding lever arm is "separately movable" in the manner claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the purpose is to "deflect or fold separately from the body portion" to overcome geometric limitations '784 Patent, col. 2:28-34 This suggests any mechanism allowing such deflection to avoid interference could be covered.
    • Evidence for a Narrower Interpretation: The patent's abstract and detailed description explicitly link this feature to a component that moves between an "extended position and a deflected position" '784 Patent, abstract A party could argue that the term requires a distinct, two-position feature, potentially limiting the scope to the specific hinged embodiment shown in Figures 2-4 and 8-10 of the patent.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges that Defendants induce infringement by "encouraging, advertising, promoting, and instructing others to use" the accused products Compl. ¶60 Compl. ¶77 Contributory infringement is alleged on the basis that the accused components "are not suitable for substantial noninfringing use as they are specially designed and adapted to be used in a fire control unit to mechanically reset a trigger mechanism" Compl. ¶62 Compl. ¶79 These allegations are repeated for all asserted patents.

Willful Infringement

  • The complaint alleges that Defendants "have known or should have known" that their actions constitute infringement and that the patents are valid Compl. ¶63 Compl. ¶80 The claim of willfulness is based on alleged pre-suit knowledge of the patents and the infringing nature of the accused products. This allegation is repeated for all asserted patents.

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

  1. Functional Operation: A central evidentiary question will be one of functional operation: do the accused "forced reset" mechanisms operate in the specific, multi-step manner required by the asserted claims? This will involve a detailed technical comparison of the interaction between the hammer, trigger, disconnector, and cam in both the "standard" and "forced reset" modes alleged for each product.
  2. Definitional Scope: The case will likely involve a critical question of definitional scope for the '784 patent: does the hinged or folding lever arm in the accused products constitute a "deflectable portion that is separately movable relative to the body portion"? The court's construction of this key term will be pivotal to determining infringement for products designed for varied firearm platforms.
  3. Patent Thicket Navigation: With nine asserted patents from the same family covering similar technological concepts, a significant challenge will be untangling the overlapping claim scopes. The case may focus on whether Defendants' single design for a trigger mechanism can be found to simultaneously infringe multiple distinct--but-related claims across this broad patent portfolio, and whether any of those claims are valid over the others.