ABC IP LLC v. Stryke Gunworks LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Stryke Gunworks LLC (South Carolina)
  • Plaintiff's Counsel: Dority & Manning, PA.
• Case Identification: 2:26-cv-02358, D.S.C., 06/17/2026
• Venue Allegations: Venue is based on the allegation that Defendant is a South Carolina limited liability company that resides in and has a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendant's "Kabuto" firearm accessory infringes four patents related to forced reset trigger mechanisms for semiautomatic firearms.
• Technical Context: The technology involves mechanical trigger assemblies that use the reciprocating motion of a firearm's bolt carrier to force the trigger to reset, enabling a faster potential rate of fire compared to standard semiautomatic triggers.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or other significant procedural events related to the asserted patents.

Case Timeline

Date	Event
2021-11-05	'784 Patent Priority Date
2022-01-10	'403 Patent Priority Date
2022-09-08	'247 Patent Priority Date
2022-09-08	'159 Patent Priority Date
2024-07-09	U.S. Patent No. 12,031,784 Issues
2024-07-16	U.S. Patent No. 12,038,247 Issues
2026-03-17	U.S. Patent No. 12,578,159 Issues
2026-05-26	U.S. Patent No. 12,636,403 Issues
2026-06-17	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: The patent background describes the desire among some firearm users to increase the rate of semiautomatic fire beyond what is typically possible with a standard trigger mechanism, where a user must consciously release the trigger to reset the sear before firing the next round '247 Patent, col. 1:41-55
• The Patented Solution: The patent discloses a "drop-in" trigger module featuring 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 In the forced reset mode, the rearward movement of the firearm's bolt carrier during the firing cycle pivots a cam, which in turn forces the trigger member back to its reset position, enabling the user to fire the next shot without first manually releasing the trigger '247 Patent, col. 6:12-40 This mechanical interaction is designed to accelerate the firing sequence '247 Patent, col. 1:10-14
• Technical Importance: The invention provides a modular, retrofittable system for converting a standard AR-pattern firearm to have a forced reset capability, a feature sought after in the civilian firearms accessory market '247 Patent, col. 2:19-27

Key Claims at a Glance

• The complaint asserts infringement of claims including, but not limited to, independent claim 15 Compl. ¶28
• Essential elements of independent claim 15 include:
  • A trigger mechanism with a hammer, trigger member, disconnector, cam, and a safety selector.
  • The safety selector is pivotal between three positions: safe, standard semi-automatic, and forced reset semi-automatic.
  • In the standard mode, the disconnector catches the hammer after a shot, requiring the user to manually release the trigger to reset the mechanism.
  • In the forced reset mode, the cycling of the bolt carrier causes the cam to force the trigger to its set position, while the safety selector prevents the disconnector from catching the hammer, allowing for an immediate subsequent trigger pull.

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

The Invention Explained

• Problem Addressed: The patent identifies a compatibility problem when installing a forced reset trigger designed for one firearm platform (e.g., an AR-15) into another with different dimensions (e.g., an AR-10) '784 Patent, col. 1:21-35 Specifically, a locking bar long enough to be actuated by the AR-10's bolt carrier would interfere with the bolt carrier as it cycles rearward, rendering the device inoperable '784 Patent, col. 1:36-44
• The Patented Solution: The invention introduces a trigger locking member with an "upwardly extending deflectable portion" '784 Patent, col. 6:4-8 This extension is long enough to be actuated by the bolt carrier as it moves into battery (unlocking the trigger), but it is designed to pivot or "fold" out of the way when the bolt carrier moves rearward, thus avoiding interference '784 Patent, abstract '784 Patent, col. 3:28-39
• Technical Importance: This design allows a forced reset trigger mechanism to be adapted for use across multiple firearm platforms with different bolt carrier geometries, increasing the technology's versatility and market applicability '784 Patent, col. 2:45-49

Key Claims at a Glance

• The complaint asserts infringement of claims including, but not limited to, independent claim 1 Compl. ¶42
• 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 includes a "body portion" and an "upwardly extending deflectable portion that is separately movable relative to the body portion."

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

• Technology Synopsis: This patent, a continuation of the application that led to the '247 Patent, describes a firearm trigger mechanism operable in both a standard semi-automatic and a forced reset semi-automatic mode '159 Patent, abstract The core problem it addresses is enabling an increased rate of fire in a semiautomatic firearm '159 Patent, col. 1:52-55 The solution involves a cam that interacts with the firearm's bolt, which in the forced reset mode, resets the trigger automatically during the firing cycle '159 Patent, col. 9:45-65
• Asserted Claims: The complaint asserts infringement of claims including, but not limited to, independent claim 1 Compl. ¶56
• Accused Features: The complaint alleges the Kabuto device, when installed, operates as a forced reset trigger with both standard and forced reset modes, utilizing a cam mechanism to reset the trigger, thereby infringing the '159 Patent Compl. ¶58

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

• Technology Synopsis: This patent also discloses a firearm trigger mechanism with selectable standard and forced reset semi-automatic modes '403 Patent, abstract It claims a combination of a hammer, disconnector, trigger member, and a safety selector that enables the two modes of operation '403 Patent, claim 38 The technical problem is again the desire to increase the rate of fire '403 Patent, col. 1:20-2:14 The solution centers on the interaction of these components, where in the forced reset mode, the trigger is mechanically reset by the action, allowing for rapid subsequent shots '403 Patent, col. 3:1-14
• Asserted Claims: The complaint asserts infringement of independent claims 38 and 54 Compl. ¶70
• Accused Features: The complaint alleges that the Kabuto product comprises a forced reset trigger mechanism with a hammer, disconnector, and trigger member that interacts with a safety selector to provide both standard and forced reset modes of operation Compl. ¶¶72-73

III. The Accused Instrumentality

Product Identification

The "Kabuto" trigger mechanism Compl. ¶23

Functionality and Market Context

The complaint alleges that the Defendant makes, uses, and sells the Kabuto, a device that embodies the technology of the asserted patents Compl. ¶23 It is allegedly sold as a partial kit via the Stryke Gunworks website Compl. ¶24 The complaint asserts that when the Kabuto's cam and cam lever components are installed in an AR-pattern firearm with other standard parts, the combination creates an infringing forced reset trigger mechanism Compl. ¶24 This mechanism can allegedly be switched between a standard semi-automatic mode and a forced reset semi-automatic mode using the firearm's safety selector Compl. ¶26 The complaint includes a photograph from Defendant's website showing the components of the Kabuto kit Compl. ¶25, p. 6

IV. Analysis of Infringement Allegations

'247 Patent Infringement Allegations

The complaint provides a claim chart alleging that the Kabuto, when installed and used as intended, infringes claim 15 of the '247 Patent. The plaintiff-generated diagrams in the complaint use color-coding to identify the accused components and their alleged function Compl. ¶30, p. 8

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a hammer having a sear catch and a hook for engaging a disconnector...	The Kabuto is installed with a hammer (Red) that has a sear catch and a hook for engaging a disconnector.	¶30	col. 8:38-42
a trigger member having a sear and adapted to be mounted...to pivot...	The Kabuto is installed with a trigger member (Brown) that has a sear and pivots.	¶30	col. 8:51-57
a disconnector having a hook for engaging said hammer...	A disconnector (Orange) is provided with a hook for engaging the hammer.	¶30	col. 8:64-9:1
a cam having a cam lobe and adapted to be...movably mounted...	The Kabuto itself (Green, Blue, and Magenta parts) is alleged to be the claimed cam with a cam lobe.	¶30	col. 9:2-9
a safety selector adapted to...pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Kabuto is designed to operate with a standard, three-position safety selector.	¶30	col. 9:48-54
whereupon in said standard semi-automatic position, rearward movement of the bolt carrier causes...disconnector hook catches said hammer hook...	The complaint alleges that in standard mode, the disconnector (Orange) catches the hammer (Red) hook after a shot, requiring a manual trigger release to reset.	¶30	col. 5:56-6:11
whereupon in said forced reset semi-automatic position...cam lobe forces said trigger member to the set position, said safety selector preventing said disconnector hook from catching said hammer hook...	The complaint alleges that in forced reset mode, the cam (Green) forces the trigger (Brown) to reset, and the safety selector prevents the disconnector (Orange) from catching the hammer hook.	¶30	col. 6:12-40

• Identified Points of Contention:
  • Scope Question: A potential issue may arise from the claim requiring "a cam," while the complaint's diagrams depict the Kabuto's allegedly infringing component as a multi-part assembly of a "cam (Green)" and a "link (Blue)" Compl. ¶30, p. 11 This raises the question of whether this assembly meets the "cam" limitation, which could become a focus of claim construction.
  • Technical Question: Infringement of the multi-mode operational steps is a factual question. The analysis will depend on evidence demonstrating that the accused product, when installed, performs the specific sequence of mechanical interactions described for both the standard and forced reset modes as claimed.

'784 Patent Infringement Allegations

The complaint alleges that the Kabuto infringes claim 1 of the '784 Patent. A color-coded diagram illustrates how the Kabuto's "lever arm" allegedly functions as the claimed "deflectable portion" Compl. ¶44, p. 22

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...and a second position where it does not restrict movement...	The Kabuto assembly (yellow, blue, and purple parts) allegedly functions as a locking member movable between a locked and an unlocked position.	¶44	col. 2:54-58
the locking member...including a generally upward extension portion configured to make actuating contact with a surface of a bolt carrier...	The Kabuto's "lever arm" (yellow) is alleged to be the upward extension that makes contact with the bolt carrier.	¶44	col. 2:61-63
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...	The Kabuto is alleged to have a body portion (blue) and an upwardly extending "lever arm" (yellow) that is separately movable. A diagram shows this separate movement Compl. ¶44, p. 24	¶44	col. 6:4-8

• Identified Points of Contention:
  • Technical Question: The core of the dispute for this patent will likely be a factual and technical one: does the accused Kabuto's "lever arm" actually function as a "deflectable portion that is separately movable relative to the body portion"? The infringement case hinges on proving this specific mechanical behavior, which is the key feature of the '784 patent.

V. Key Claim Terms for Construction

For the '247 Patent

• The Term: "a cam"
• Context and Importance: This term is critical because claim 15 requires "a cam having a cam lobe," while the complaint's infringement theory appears to map this limitation onto a multi-part assembly within the accused Kabuto device Compl. ¶30, p. 11 Practitioners may focus on this term because its construction will determine whether a multi-component assembly can meet a limitation reciting a single component.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the cam functionally, in terms of its interaction with the cam follower and its role in resetting the trigger '247 Patent, col. 9:16-24 A party might argue that any mechanical structure performing this function, regardless of its piece count, constitutes "a cam." The specification also mentions the cam "can be slidably mounted... with or without spring bias," suggesting some flexibility in its form '247 Patent, col. 9:10-12
  • Evidence for a Narrower Interpretation: The embodiments depicted in the patent consistently show the cam (72) as a single, unitary component '247 Patent, Fig. 3 '247 Patent, Fig. 8 A party could argue that the term "a cam" should be limited to the single-piece structure illustrated and described, and that a multi-part assembly is a different structure.

For the '784 Patent

• The Term: "deflectable portion that is separately movable"
• Context and Importance: This phrase defines the central inventive concept of the '784 patent-the solution to the bolt carrier interference problem. The infringement analysis will turn on whether the accused Kabuto device possesses a feature that meets this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the feature functionally as a "deflectable extension...that...deflects or folds to avoid interfering contact" '784 Patent, col. 2:45-49 The specification also mentions an alternative embodiment of a "sliding locking member" that is "deflectable," which may suggest the term is not limited to a purely pivoting motion '784 Patent, col. 4:59-65
  • Evidence for a Narrower Interpretation: The detailed description repeatedly refers to the feature as a "foldable extension portion" that "pivots on...a transverse pivot pin" '784 Patent, col. 3:42-44 The figures exclusively show a hinged, pivoting component '784 Patent, Figs. 2-4 '784 Patent, Figs. 8-10 A party may argue that "separately movable" should be construed as being limited to the hinged or pivoting movement explicitly disclosed in the embodiments.

VI. Other Allegations

• Indirect Infringement: For all asserted patents, the complaint alleges both induced and contributory infringement. The inducement allegation is based on Defendant's alleged advertising and instructions on how to install and use the Kabuto Compl. ¶31 Compl. ¶45 Compl. ¶59 Compl. ¶74 The contributory infringement allegation asserts that the Kabuto's components have no substantial non-infringing use and are specially designed to be used in a manner that infringes the patents Compl. ¶33 Compl. ¶47 Compl. ¶61 Compl. ¶76
• Willful Infringement: Willfulness is alleged for all four patents. The complaint claims Defendant "has known or should have known" that its actions infringe and continued its activities despite this knowledge Compl. ¶34 Compl. ¶48 Compl. ¶62 Compl. ¶77 The allegations state this knowledge exists "at least through the service of this complaint," establishing a basis for potential post-suit willfulness.

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

1. Definitional Scope and Equivalence: A primary issue will be one of claim construction: for the '784 Patent, can the term "separately movable deflectable portion," which the patent illustrates as a pivoting hinge, be construed to read on the accused Kabuto's mechanism? Similarly, for the '247 family of patents, does the accused device's multi-part cam and link assembly meet the "a cam" limitation, or will an argument under the doctrine of equivalents be necessary?
2. Indirect Infringement and Commercial Application: As the accused product is a kit sold to end-users for installation, Plaintiffs' case appears to rely heavily on theories of indirect infringement. A central question will be one of substantial non-infringing use: can the Defendant demonstrate that the components of the Kabuto kit have commercially significant uses that do not infringe the asserted patents, which would challenge the contributory infringement claim?
3. Mode-Specific Operation: The asserted claims require the trigger mechanism to perform a specific sequence of functions in both a "standard" and a "forced reset" mode. A key evidentiary question will be one of operational proof: can Plaintiffs provide sufficient evidence to demonstrate that the accused Kabuto, when installed in a firearm, meets every claimed functional limitation in both of the required operational modes?