DCT

6:26-cv-03955

ABC IP LLC v. Upstate Triggers LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:26-cv-03955, D.S.C., 09/08/2026
  • Venue Allegations: Venue is alleged to be proper because Defendants reside in, have committed acts of infringement in, and have a regular and established place of business in the District of South Carolina.
  • Core Dispute: Plaintiffs allege that Defendants’ "Drop In FRD" firearm trigger infringes four patents related to "forced reset" trigger mechanisms, and further allege trademark infringement related to Plaintiffs' "FRT" mark.
  • Technical Context: The technology concerns firearm trigger mechanisms for semi-automatic platforms like the AR-15, designed to increase the potential rate of fire by using the firearm's cycling action to mechanically reset the trigger.
  • Key Procedural History: The complaint alleges that Plaintiff Rare Breed has used the "FRT®" trademark to identify a unique trigger for firearms since at least 2020. No other significant procedural history is mentioned.

Case Timeline

Date Event
2020-01-01 Approximate start of Plaintiff's use of FRT trademark
2021-11-05 Priority Date for ’784 Patent
2022-01-10 Priority Date for ’403 Patent
2022-09-08 Priority Date for ’247 Patent and ’159 Patent
2024-07-09 '784 Patent Issued
2024-07-16 '247 Patent Issued
2026-03-17 '159 Patent Issued
2026-05-26 '403 Patent Issued
2026-09-08 Complaint Filed

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. ¶15

The Invention Explained

  • Problem Addressed: The patent describes a desire among some shooters to increase the rate of semi-automatic fire beyond what is typically possible with a standard trigger mechanism, which requires a user to manually release the trigger to reset the sear and disconnector after each shot ’247 Patent, col. 1:19-40 Conventional methods like "bump firing" are noted as one way users attempt to achieve this ’247 Patent, col. 1:41-55
  • The Patented Solution: The invention provides a "drop-in" trigger module with multiple, selectable modes of operation: a standard semi-automatic mode and a "forced reset" semi-automatic mode ’247 Patent, abstract In the forced reset mode, the rearward movement of the firearm's bolt carrier causes a pivoting cam to force the trigger member back to its set position, allowing the user to fire another round immediately upon the action returning to battery, without needing to manually release pressure on the trigger ’247 Patent, col. 2:54 - col. 3:10
  • Technical Importance: The technology provides a self-contained, user-selectable mechanism to significantly increase the potential rate of fire in a semi-automatic firearm by mechanically linking the trigger reset function to the action's cycle ’247 Patent, col. 2:16-28

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶43
  • The essential elements of 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, after firing, a user must manually release the trigger member to free the hammer from the disconnector to permit the next shot.
    • The mechanism is also operable in a "forced reset semi-automatic mode" where, after firing, the cam is in a second position, and rearward movement of the bolt carrier causes the disconnector hook to be prevented from catching the hammer hook, allowing the user to pull the trigger again to fire the firearm.
  • The complaint reserves the right to assert other claims Compl. ¶42

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. ¶16

The Invention Explained

  • Problem Addressed: The patent explains that prior art forced reset triggers designed for one firearm platform (e.g., AR-15) may not be operable in another platform with different dimensions (e.g., AR-10). Specifically, a locking member tall enough to be actuated by an AR-10 bolt carrier might interfere with the forward portion of that same carrier as it cycles rearward, rendering the device inoperable ’784 Patent, col. 1:21-44
  • The Patented Solution: The invention is an extended trigger locking device with an "upwardly extending deflectable portion." This upper portion is rigid when pushed from the rear by the bolt carrier (to unlock the trigger) but is designed to fold, hinge, or deflect out of the way when contacted from the front by the lower surface of the bolt carrier as it cycles to the rear, thus avoiding interference ’784 Patent, abstract ’784 Patent, col. 2:1-10
  • Technical Importance: This "one-way hinge" design allows the core concept of a forced reset trigger to be adapted for use in a wider variety of semi-automatic firearms that have different internal geometries and bolt carrier dimensions ’784 Patent, col. 1:45-49

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶57
  • The essential elements of claim 1 include:
    • An extended trigger member locking device for a forced rest trigger mechanism.
    • The device includes a locking member movable between a first (locking) and second (non-restricting) position.
    • 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.
    • Actuating contact with the bolt carrier causes the locking member to move from the first to the second position.
  • The complaint reserves the right to assert other claims Compl. ¶56

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 ’159 Patent Compl. ¶17
  • Technology Synopsis: This patent discloses a firearm trigger mechanism for a firearm with a reciprocating bolt, operable in a "standard semi-automatic mode" and a "forced reset semi-automatic mode" ’159 Patent, claim 1 The mechanism comprises a hammer, trigger member, disconnector, and a cam that, in the forced reset mode, uses the bolt's movement to force the trigger toward its set position, enabling an accelerated rate of fire Compl. ¶¶26-27
  • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶71
  • Accused Features: The "Drop In FRD" is alleged to be a trigger mechanism that operates in both a standard and a "forced reset" semi-automatic mode by using a bolt means to reset the trigger, thereby infringing the '159 Patent Compl. ¶72

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 ’403 Patent Compl. ¶18
  • Technology Synopsis: This patent claims a forced reset trigger mechanism comprising a hammer, disconnector, trigger member, and a safety selector that is movable between a "standard semi-automatic position" and a "forced reset semi-automatic position" ’403 Patent, claim 38 The position of the safety selector dictates whether the user must manually reduce pressure to reset the trigger (standard mode) or whether the firearm's action will forcibly return the trigger to a set position (forced reset mode) Compl. ¶29
  • Asserted Claims: The complaint asserts independent claims 38 and 54 Compl. ¶84
  • Accused Features: The "Drop In FRD" is alleged to infringe by being a forced reset trigger that includes a safety selector for moving between a standard and forced reset mode Compl. ¶¶86-87

III. The Accused Instrumentality

Product Identification

  • The accused product is the "Drop In FRD device" ("the Drop In FRD") Compl. ¶31

Functionality and Market Context

  • The complaint alleges the Drop In FRD is a trigger mechanism that can operate in at least two modes: a "disconnector mode" similar to a standard AR-15 trigger, and a "forced reset" semi-automatic mode Compl. ¶34 A user allegedly switches between these modes by rotating the firearm's safety selector Compl. ¶34
  • Defendants are alleged to make, use, sell, and offer for sale the Drop In FRD through the website upstatetriggers.us and to various firearms dealers in South Carolina Compl. ¶32 The complaint includes a screenshot from this website showing a map of dealers, described as "In-Store Locations" Compl. p. 8

IV. Analysis of Infringement Allegations

'247 Patent Infringement Allegations

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 Drop In FRD is installed with a hammer (red) that has a sear catch and a hook for engaging a disconnector (orange). The complaint provides a rendering of the accused hammer and disconnector. ¶44 (p. 14) col. 7:48-50
a trigger member having a sear... The Drop In FRD is installed with a trigger member (brown) that has a sear. ¶44 (p. 16) col. 7:51-53
and a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, The Drop In FRD allegedly has a cam (green) with a cam lobe and a lever that is movably mounted in the fire control mechanism pocket. A diagram labels the parts of the accused cam. ¶44 (p. 18) col. 8:1-3
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 alleged to be movable. In its second position, the cam lobe (green) moves the trigger member (brown) via a link (blue) toward the set position when in "forced reset" mode. ¶44 (p. 19) col. 9:1-12
whereupon in a standard semi-automatic mode... rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook, In standard mode, rearward movement of the bolt carrier allegedly causes the hammer (red) to pivot rearward so that the disconnector hook (orange) catches the hammer hook. ¶44 (p. 21) col. 9:13-23
whereupon in a forced reset semi-automatic mode... rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook, In forced reset mode, the cam is in its second position, and rearward movement of the bolt carrier allegedly causes the hammer to pivot while the disconnector hook is prevented from catching it. This is illustrated in a diagram. ¶44 (p. 23) col. 9:55-67

'784 Patent Infringement Allegations

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 against pulling movement and a second position where it does not restrict movement... The Drop In FRD is alleged to operate as a locking member, moving between a "Locked First Position" and an "Unlocked Second Position." ¶58 (p. 28) col. 3:55-61
...including a generally upward extension portion configured to make actuating contact with a surface of a bolt carrier... The Drop In FRD allegedly has an upward extending "lever arm" (yellow) that makes actuating contact with the bolt carrier. ¶58 (p. 29) col. 3:61-65
...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 Drop In FRD allegedly has a body portion (blue) and an upwardly extending deflectable portion, or "lever arm" (yellow). An overlay diagram is provided to show the lever arm's separate travel relative to the body. ¶58 (p. 31) col. 2:1-10; col. 4:3-8
  • Identified Points of Contention:
    • Technical Questions: A central technical question for the '247 patent will be whether the accused Drop In FRD operates in the precise sequence claimed. For example, does the accused cam "force" the trigger member to reset in the claimed manner, or does it merely enable a spring to do so? For the '784 patent, a key dispute may be whether the accused device’s "lever arm" is "separately movable" and "deflectable" as those terms are used in the patent, or if its movement is coupled with the main body in a way that avoids infringement.
    • Scope Questions: The case may raise questions about the scope of functional language. For the '247 patent, does the accused device's "standard" mode meet all the functional limitations of the claimed "standard semi-automatic mode," including the requirement that a user "must manually release said trigger member"?

V. Key Claim Terms for Construction

'247 Patent

  • The Term: "forces said trigger member towards said set position"
  • Context and Importance: This term from claim 15 is crucial for defining the "forced reset" action. The infringement analysis will depend on whether the accused cam is the agent causing the trigger reset, as "forces" implies, or if it merely facilitates a reset driven by other components, such as a spring. Practitioners may focus on this term because it distinguishes the invention from mechanisms where a cam might simply unblock the trigger's reset path.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent repeatedly uses active language like "forces the trigger to the set position" and "forcing the rear of the trigger down," suggesting any action by the cam that directly results in the trigger moving to set position would suffice ’247 Patent, col. 2:2-13
    • Evidence for a Narrower Interpretation: A defendant might argue that because the trigger member is also described as being "spring biased" ’247 Patent, col. 7:59-62, the term "forces" must mean that the cam provides the principal or sole motive force for the reset, distinguishing it from the inherent bias of the trigger's own spring.

'784 Patent

  • The Term: "separately movable relative to the body portion"
  • Context and Importance: This term from claim 1 defines the novelty of the adaptable locking member. The case may turn on how much independence of movement is required for the "deflectable portion" relative to the "body portion." A plaintiff would likely argue for a broad definition covering any relative motion, while a defendant might argue it requires a specific, decoupled pivot. The complaint provides a visual on page 32 that explicitly illustrates the "total separate travel" of the lever arm, indicating this is a key point of the plaintiff's infringement theory.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not specify the degree of separate movement, suggesting any relative motion could qualify. The specification's goal of allowing the bolt carrier to pass "without displacing the locking bar body" ’784 Patent, col. 4:30-31 supports an interpretation where the key is avoiding movement of the main body.
    • Evidence for a Narrower Interpretation: The patent illustrates the feature as a distinct component pivoting on a pin ’784 Patent, Fig. 2 ’784 Patent, col. 4:1-2 A defendant could argue this embodiment limits the term "separately movable" to a discrete, hinged component, as opposed to a flexible or partially coupled member.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants induce infringement by advertising and providing instructions on how to install and use the Drop In FRD Compl. ¶45 Compl. ¶59 Contributory infringement is alleged on the basis that components of the Drop In FRD, such as the cam, are specially designed for an infringing purpose and are not suitable for substantial noninfringing use Compl. ¶47 Compl. ¶61
  • Willful Infringement: Willfulness is alleged for all four patents based on Defendants having "known or should have known" that their actions constituted infringement Compl. ¶48 Compl. ¶62 Compl. ¶76 Compl. ¶91 The complaint asserts that Defendants could not have formed a reasonable belief that their actions did not constitute infringement or that the patents were invalid Compl. ¶48

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

  1. A core issue will be one of mechanical and sequential equivalence: Does the accused "Drop In FRD" device, when operated in its different modes, follow the precise sequence of mechanical interactions—catching, releasing, forcing, and preventing—as recited in the functional limitations of the asserted claims, particularly those in the '247 and '159 patents? The analysis will likely depend on a frame-by-frame comparison of the competing mechanisms.
  2. A second key issue will be one of structural scope: For the '784 patent, can the term "separately movable relative to the body portion," which was designed to solve an interference problem in specific firearm platforms, be construed to read on the accused device's "lever arm"? This question will require the court to determine the boundary between a single, flexible component and two "separately movable" parts.
  3. A final question will center on the role of the safety selector: For the '403 patent, the infringement analysis will focus on whether the accused device's safety selector is the component that enables or disables the "forced reset" functionality in the manner claimed, potentially creating a separate point of infringement liability distinct from the core trigger components.