DCT

2:26-cv-00038

ABC IP LLC v. Stark80 LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00038, M.D. Tenn., 06/13/2026
  • Venue Allegations: Venue is alleged to be proper because the Defendants reside in, have committed acts of infringement in, and/or have a regular and established place of business in the district.
  • Core Dispute: Plaintiffs allege that Defendants' firearm trigger modification kits infringe nine U.S. patents related to "forced reset" trigger mechanisms that increase the semi-automatic rate of fire.
  • Technical Context: The technology concerns aftermarket trigger mechanisms for AR-15-pattern firearms, which use the cycling of the firearm's action to mechanically reset the trigger, allowing for a faster rate of fire than standard semi-automatic triggers.
  • Key Procedural History: The complaint alleges that Plaintiff ABC is the owner by assignment of the Asserted Patents and that Plaintiff Rare Breed is the exclusive licensee. The complaint does not mention any prior litigation or post-grant proceedings involving the Asserted Patents.

Case Timeline

Date Event
2017-09-29 Priority Date for U.S. Patent No. 10,514,223
2019-12-24 U.S. Patent No. 10,514,223 Issued
2020-01-01 Approximate date from which Plaintiffs claim use of "FRT" trademark
2021-11-05 Priority Date for U.S. Patent No. 12,031,784
2022-01-10 Priority Date for U.S. Patent Nos. 11,724,003, 12,036,336, 12,274,807, 12,636,403
2022-09-08 Priority Date for U.S. Patent Nos. 12,038,247, 12,578,159
2023-08-15 U.S. Patent No. 11,724,003 Issued
2023-12-04 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
2026-06-13 Complaint Filed

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

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

The Invention Explained

  • Problem Addressed: The complaint explains that in a standard semi-automatic firearm, the user must manually release the trigger to reset the sear, which limits the rate of fire because the user cannot typically reset the trigger faster than the bolt cycles Compl. ¶¶26-27
  • The Patented Solution: The invention is a trigger mechanism that can be selected to operate in a "forced reset" mode Compl. ¶29 In this mode, the cycling of the firearm's action rotates a cam, which in turn "cause[s] the trigger member to reset and prevent the trigger member from being pulled again until the action has returned to the in-battery position" '247 Patent, abstract This allows for an accelerated rate of fire without needing a disconnector to catch the hammer Compl. ¶28 '247 Patent, abstract
  • Technical Importance: This design provides a mechanical method to significantly increase the rate of fire of a semi-automatic firearm using a selectable trigger mechanism.

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶66
  • The essential elements of claim 15 include:
    • A firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a cam, operable in a standard semi-automatic mode and a forced reset semi-automatic mode.
    • The cam is movable between a first position (for standard mode) and a second position (for forced reset mode).
    • In standard mode, rearward bolt carrier movement causes the disconnector to catch the hammer, requiring the user to manually release the trigger to fire again.
    • In forced reset mode, the cam lobe forces the trigger member toward its set position.
    • In forced reset mode, rearward bolt carrier movement causes the disconnector hook to be prevented from catching the hammer hook, allowing the user to pull the trigger again once the bolt is in battery without first manually releasing it.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" Compl. ¶66

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

The Invention Explained

  • Problem Addressed: The complaint alleges that this invention overcomes "geometric limitations of prior art designs for use in multiple and varied semi-automatic firearm designs" Compl. ¶30 The patent's background notes that a locking member tall enough to be actuated by an AR-10 bolt carrier would interfere with the bolt carrier's forward portion as it cycles rearward '784 Patent, col. 1:40-49
  • The Patented Solution: The patent describes an "extended trigger member locking mechanism" that has a "deflectable extension" '784 Patent, abstract Compl. ¶30 This extension is actuated by the forward movement of the bolt carrier but can "deflect or fold separately from the body portion of the locking member" to avoid interference when the bolt carrier cycles to the rear Compl. ¶30 '784 Patent, col. 2:3-12
  • Technical Importance: This design allows a forced reset-style trigger mechanism to be adapted for different firearm platforms (e.g., AR-10) with varying internal geometries, which prior rigid designs could not accommodate.

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶83
  • The essential elements of 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 an upward extension to make "actuating contact" with the bolt carrier, causing the member to move from the first to the second position.
    • The locking member 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 does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" Compl. ¶83

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

  • Patent Identification: 12,529,538, "Safety Mechanism for Firearm", issued January 20, 2026.
  • Technology Synopsis: The complaint describes the '538 Patent as providing a safety mechanism for a firearm that uses a "cam selector, a lever, and a trigger" Compl. ¶31 The cam selector has multiple recesses and operates in 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, and a third mode that prevents the trigger from being pulled Compl. ¶31
  • Asserted Claims: Claim 1 is asserted Compl. ¶100
  • Accused Features: The "Super Safety" product is accused of infringing this patent Compl. ¶36

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

  • Patent Identification: 12,578,159, "Firearm Trigger Mechanism", issued March 17, 2026.
  • Technology Synopsis: The '159 Patent is described as providing a "novel device for accelerating the firing sequence" of a semi-automatic firearm, similar to the '247 Patent Compl. ¶29 It uses a cam, rotated by the action's cycling, to reset the trigger and allows selection between a standard mode and a "forced reset" mode Compl. ¶29
  • Asserted Claims: Claim 1 is asserted Compl. ¶114
  • Accused Features: The "Super Safety," "MARC Selector," "ARC-Fire," and "Kabuto" products are accused of infringing this patent Compl. ¶114

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

  • Patent Identification: 10,514,223, "Firearm Trigger Mechanism", issued December 24, 2019.
  • Technology Synopsis: The complaint states the '223 Patent claims a device where the cycling of the action causes the hammer to contact the trigger member, which "mechanically reset[s] the hammer and trigger member" Compl. ¶32 A locking bar prevents the trigger from being pulled again until the bolt carrier is in battery Compl. ¶32
  • Asserted Claims: Claim 4 is asserted Compl. ¶131
  • Accused Features: "The Disruptor" product is accused of infringing this patent Compl. ¶44 Compl. ¶131

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

  • Patent Identification: '003 Patent (Aug. 15, 2023), '336 Patent (July 16, 2024), '807 Patent (Apr. 15, 2025), and '403 Patent (May 26, 2026).
  • Technology Synopsis: The complaint groups these four patents, stating they "describe and claim a similarly operating device" with the feature of being selectable between two modes: "1) standard disconnector semiautomatic mode and 2) 'forced reset' semiautomatic mode" Compl. ¶33
  • 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. ¶¶145; Compl. ¶159; Compl. ¶172; Compl. ¶186).
  • Accused Features: "The Disruptor" is accused of infringing the '003, '336, and '807 patents Compl. ¶44 The "Super Safety," "MARC Selector," "Disruptor," "ARC-Fire," and "Kabuto" are accused of infringing the '403 patent Compl. ¶186

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are five firearm trigger products: "The Super Safety," "The MARC Selector," "The Disruptor," "The ARC-Fire," and "The Kabuto" (Compl. ¶¶36; Compl. ¶40; Compl. ¶44; Compl. ¶51; Compl. ¶55). They are sold as either a "partial kit" or a "complete kit" Compl. ¶37

Functionality and Market Context

  • The complaint alleges these products are trigger mechanisms for AR-15-style firearms that allow the user to switch between different modes of operation (Compl. ¶¶39; Compl. ¶43; Compl. ¶47; Compl. ¶54; Compl. ¶58). These modes include a "standard semiautomatic with disconnector" mode and a "'forced reset' semiautomatic with cam" mode, which is achieved by moving or rotating a safety selector (Compl. ¶¶39; Compl. ¶43). The complaint includes a screenshot from the Defendants' website showing a disclaimer that its products are independently designed and that any reference to Plaintiffs' "FRT" or "forced reset trigger" products is for descriptive and compatibility purposes Compl. p. 6 Product images from Defendants' website show the various accused kits for sale Compl. ¶38 Compl. ¶42 Compl. ¶46 Compl. ¶53

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... The complaint alleges that the accused Super Safety, when installed, is part of a trigger mechanism and functions as a cam. ¶68 col. 11:15-19
said cam being movable between a first position and a second position, The accused Super Safety cam is alleged to be movable between a first and second position. The complaint includes a plaintiff-generated rendering of the cam moving between positions. (Compl. p. 22) ¶68 col. 12:2-3
in said second position said cam lobe forces said trigger member towards said set position, The complaint alleges that in the "forced reset" mode, the cam lobe mechanically moves the trigger member toward the set position. ¶68 col. 12:3-5
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 mode, the cam is in its first position, and the rearward movement of the bolt carrier causes the disconnector to catch the hammer hook. ¶68 col. 12:6-11
...at which time a user must manually release said trigger member to free said hammer from said disconnector to permit said hammer and trigger member to pivot to said set positions so that the user can pull said trigger member to fire the firearm, and The user must manually release the trigger to free the hammer from the disconnector and reset the trigger to fire again. ¶68 col. 12:11-17
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, When in "forced reset" mode, the cam is in its second position, and rearward bolt movement pivots the hammer such that the disconnector hook is prevented from catching it. ¶68 col. 12:18-24
...at which time the user can pull said trigger member to fire the firearm. The user can then pull the trigger to fire the weapon. ¶68 col. 12:26-27
  • Identified Points of Contention:
    • Scope Questions: A central question may be the construction of "cam." The defense could argue that the accused component, although performing a similar function, does not meet the structural or functional definition of a "cam" as understood in the patent. The dispute may center on whether the accused "cam" truly "forces" the trigger member in the manner claimed.
    • Technical Questions: The analysis will likely require a detailed, frame-by-frame examination of the accused products' operation in both "standard" and "forced reset" modes to determine if the sequence of events-particularly the disconnector being "prevented from catching said hammer hook"-is identical to the sequence required by the claim.

'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... The complaint alleges the Super Safety operates as a locking member movable between a locked first position and an unlocked second position. The complaint includes plaintiff-generated renderings showing these two positions. (Compl. p. 63) ¶85 col. 5:14-20
...and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, such actuating contact causing the locking member to move from the first position to the second position, The Super Safety is alleged to have an upward extending lever arm that makes contact with the bolt carrier, causing the locking member to move from the locked to the unlocked position. ¶85 col. 5:23-28
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 complaint alleges the MARC Selector (another accused product) has a body portion and an upwardly extending "deflectable portion (lever arm)" that is separately movable. ¶86 col. 6:3-9
  • Identified Points of Contention:
    • Scope Questions: The core of the dispute for the '784 Patent will likely be the term "upwardly extending deflectable portion that is separately movable." The court will need to determine the structural and functional requirements of this term. Questions will arise as to whether the accused products' components exhibit both "deflection" and "separate movability" relative to the main body of the locking member, as opposed to, for example, a unitary pivoting motion.
    • Technical Questions: Evidence will be needed to show whether the accused locking mechanism's arm deflects independently of its main body to allow the bolt carrier to pass, or if the entire mechanism pivots as a single unit. The distinction between a "deflected position" and the normal range of motion of a simple pivoting lever will be a key factual issue.

V. Key Claim Terms for Construction

  • Patent: '247 Patent

    • The Term: "cam"
    • Context and Importance: The "cam" is the central component alleged to enable the "forced reset" mode. Its interaction with the trigger member is critical to the infringement theory. Practitioners may focus on this term because its definition will determine whether the accused mechanism's method of resetting the trigger falls within the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit, limiting definition of "cam." The claims describe its function-being "movable" and having a "lobe" that "forces" the trigger member (Claim 15). A party could argue any component with a lobe that converts rotary motion into linear motion to force the trigger reset meets this functional definition.
      • Evidence for a Narrower Interpretation: The figures in the '247 patent depict a specific rotating component. A party could argue that the term "cam" should be limited to the structure shown in the embodiments, potentially excluding dissimilar structures in the accused devices even if they achieve a similar result.

  • Patent: '784 Patent

    • The Term: "deflectable portion that is separately movable"
    • Context and Importance: This term appears to be the point of novelty intended to overcome geometric limitations in prior art for different firearm platforms. Infringement hinges on whether the accused device's locking arm is merely a simple lever or if it has this specific "deflectable" and "separately movable" quality.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification uses the phrase "deflect or fold separately" Compl. ¶30, suggesting the term could cover a range of motions, including simple pivoting on a hinge, as long as it is separate from the main body's movement. The '784 patent states the portion is "separately movable...between an extended position and a deflected position" (col. 6:7-9).
      • Evidence for a Narrower Interpretation: The term "deflectable" could be construed to require some degree of material flexing or bending, rather than simple, rigid pivoting. The detailed description mentions a "one-way hinge feature" '784 Patent, col. 2:6-7 and shows specific hinged embodiments (e.g.,'784 Patent, Figs. 8-10). A party could argue the claims should be limited to such hinged structures, and not read on any component that simply pivots as a whole.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on Defendants allegedly "instructing others to use and/or how to use" the accused products through "installation of, encouraging, advertising, [and] promoting" them Compl. ¶72 Compl. ¶89 Contributory infringement is based on the allegation that the sold components are "specially designed and adapted to be used in a fire control unit to mechanically reset a trigger mechanism" and are thus "not suitable for substantial noninfringing use" Compl. ¶74 Compl. ¶91
  • Willful Infringement: Willfulness is alleged based on Defendants' knowledge of the patents. The complaint asserts this knowledge existed "at least when the language referencing Plaintiffs was added to their website and/or through the service of Plaintiffs' Complaint" Compl. ¶75 Compl. ¶92 This pleading suggests a theory of both pre-suit knowledge (from awareness of Plaintiffs' products) and definite post-suit knowledge.

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

This case presents a complex, multi-patent dispute over firearm trigger technology. The outcome will likely depend on the court's resolution of several central questions:

  • A primary issue will be one of claim construction and scope: can the term "deflectable portion that is separately movable" from the '784 patent be construed to cover the pivoting lever-arm mechanisms of the accused products, or is it limited to a more specific hinged or flexing structure? Similarly, the definition of "cam" in the '247 patent and whether it reads on the accused components will be critical.

  • A key evidentiary question will be one of operational equivalence: do the accused "forced reset" trigger kits function in the precise sequence claimed in the patents? This will involve a technical, step-by-step comparison of the interaction between the hammer, disconnector, and cam/locking member in the accused products versus the sequence mandated by the asserted claims.

  • A third question will concern willfulness and damages: should infringement be found, the court will need to determine when Defendants' knowledge of the patents attached-whether through awareness of Plaintiffs' commercial products or upon receiving the complaint-and whether their continued sales constituted willful infringement justifying enhanced damages.

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