ABC IP LLC v. Burse

I. Executive Summary and Procedural Information

• Parties & Counsel:

  • Plaintiff: ABC IP, LLC (Delaware); Rare Breed Triggers, Inc. (Texas); and RBTM LLC (Wyoming)
  • Defendant: Jacob Rusty Burse D/B/A Shackleford's FRT (Tennessee)
  • Plaintiff's Counsel: Spears, Moore, Rebman & Williams, P.C.

• Case Identification: 1:26-cv-01118, W.D. Tenn., 05/29/2026

• Venue Allegations: Venue is alleged to be proper as the Defendant resides in, has committed acts of infringement in, and maintains a regular and established place of business within the district.

• Core Dispute: Plaintiffs allege that Defendant's "Super Safety" aftermarket firearm trigger systems infringe five patents related to forced reset trigger mechanisms.

• Technical Context: The technology concerns trigger mechanisms for semi-automatic firearms, specifically "forced reset triggers," which use the firearm's cycle of operation to mechanically reset the trigger, enabling a faster rate of fire than standard designs.

• 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
2021-11-05	U.S. Patent No. 12,031,784 Priority Date
2022-01-10	U.S. Patent No. 12,636,403 Priority Date
2022-09-08	U.S. Patent Nos. 12,038,247 & 12,578,159 Priority Date
2023-12-04	U.S. Patent No. 12,529,538 Priority Date
2024-07-09	U.S. Patent No. 12,031,784 Issued
2024-07-16	U.S. Patent No. 12,038,247 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
2026-05-29	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 addresses the desire among some shooters to increase the rate of fire of a semi-automatic firearm, which is limited by the need to manually release the trigger to reset the firing mechanism after each shot Compl. ¶21 '247 Patent, col. 1:39-50
• The Patented Solution: The invention is a "drop-in" trigger module for an AR-pattern firearm that provides three selectable modes: safe, standard semi-automatic, and "forced reset" semi-automatic Compl. ¶23 '247 Patent, abstract In the forced reset mode, the rearward motion of the firearm's bolt carrier actuates a pivoting cam, which in turn physically forces the trigger member back to its reset position '247 Patent, col. 9:44-51 Simultaneously, a feature on the safety selector prevents the disconnector from catching the hammer, allowing the user to fire again immediately without having to release the trigger Compl. ¶23 '247 Patent, col. 9:35-43
• Technical Importance: This design provides a self-contained module that enables a significantly increased rate of fire in a widely used firearm platform without requiring modification of other core components like the bolt carrier '247 Patent, col. 2:23-28

Key Claims at a Glance

• The complaint asserts independent claim 15 Compl. ¶40
• The essential elements of claim 15 include:
  • A trigger mechanism comprising a hammer, a trigger member, a disconnector, a cam, and a three-position safety selector (safe, standard semi-automatic, forced reset) '247 Patent, col. 10:21-50
  • In the standard semi-automatic mode, the disconnector catches the hammer after a shot, requiring the user to manually release the trigger to reset the mechanism '247 Patent, col. 10:51-11:1
  • In the forced reset semi-automatic mode, the cycling 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 the user to fire again without releasing the trigger '247 Patent, col. 11:2-11
• The complaint reserves the right to assert other claims Compl. ¶40

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

The Invention Explained

• Problem Addressed: The patent identifies that prior forced reset trigger designs, while functional in AR15-pattern firearms, are not operable in other platforms like the AR10 due to different bolt carrier geometries. An extended locking bar long enough to be actuated by an AR10's bolt would interfere with another part of the same bolt during its cycle '784 Patent, col. 1:20-44
• The Patented Solution: The invention is a trigger locking device with an upward extension that is "separately movable" from the main body of the locking member, for instance via a "one-way hinge" '784 Patent, col. 2:62-63 This allows the extension to be long enough to be actuated by the bolt carrier upon returning to battery, but also to deflect or fold out of the way to avoid interference as the bolt carrier cycles rearward '784 Patent, abstract '784 Patent, col. 3:25-35
• Technical Importance: This design expands the applicability of forced reset trigger technology to a wider variety of semi-automatic firearms that have different internal geometries and dimensional specifications Compl. ¶24

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶54
• The essential elements of claim 1 include:
  • A locking member movable between a first (locking) and second (non-locking) position, actuated by contact with a bolt carrier '784 Patent, col. 5:12-6:4
  • The locking member has a movably supported body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion" '784 Patent, col. 6:4-9
• The complaint reserves the right to assert other claims Compl. ¶54

U.S. Patent No. 12,529,538 - "Safety Mechanism for Firearm," issued January 20, 2026

• Patent Identification: U.S. Patent No. 12,529,538, "Safety Mechanism for Firearm," issued January 20, 2026 Compl. ¶12
• Technology Synopsis: The patent describes a safety mechanism centered on a multi-profiled cam selector that provides three operational modes. The selector has a cylindrical body with distinct recesses on its bottom side that interact with the tail of the trigger. In the second, "active reset" mode, rotation of the cam causes a cam portion to engage and push down on the trigger tail, forcing a reset Compl. ¶25 '538 Patent, abstract
• Asserted Claims: Independent claim 1 Compl. ¶68
• Accused Features: The complaint alleges the accused "Super Safety" embodies the claimed three-mode cam selector, where different rotational positions of the selector enable safe, standard semi-automatic, and active reset functions Compl. ¶¶29, 32, 70

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

• Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism," issued March 17, 2026 Compl. ¶13
• Technology Synopsis: This patent, related to the '247 patent, claims a firearm trigger mechanism operable in a standard semi-automatic mode and a forced reset semi-automatic mode. The invention uses a cam, actuated by the firearm's "reciprocating bolt means," to force the trigger member back to its set position, allowing for an accelerated rate of fire Compl. ¶23 '159 Patent, abstract
• Asserted Claims: Independent claim 1 Compl. ¶82
• Accused Features: The complaint alleges the accused "Super Safety" infringes by implementing the claimed dual-mode functionality, where a cam mechanism forces the trigger to reset in one of its operational modes Compl. ¶¶29, 32, 84

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

• Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism," issued May 26, 2026 Compl. ¶14
• Technology Synopsis: This patent describes a trigger mechanism with a safety selector that is movable between a standard semi-automatic position and a forced reset semi-automatic position. In the standard mode, the user must reduce pressure on the trigger to permit reset. In the forced reset mode, the mechanism is configured to reset automatically upon action of the bolt carrier, allowing the user to fire again without reducing pressure Compl. ¶26 '403 Patent, abstract
• Asserted Claims: Independent claim 38 Compl. ¶96
• Accused Features: The complaint alleges the accused "Super Safety" infringes by incorporating a safety selector that allows the user to switch between a standard mode and a forced reset mode, matching the functionality described in the patent Compl. ¶¶29, 32, 98

III. The Accused Instrumentality

• Product Identification: The accused products are the "(3-Position) 'Super Safety'" trigger mechanisms sold by the Defendant Compl. ¶29
• Functionality and Market Context: The "Super Safety" is sold as a component kit or pre-installed in a firearm receiver, designed for use in AR-pattern firearms Compl. ¶30 The complaint alleges the product provides three selectable modes of operation: a safe position, a standard semi-automatic mode (termed "disconnector mode"), and a forced reset semi-automatic mode Compl. ¶32 The core of the accused functionality involves using "cam and cam lever components" which, when installed, create a forced reset trigger mechanism Compl. ¶30a The complaint includes a photograph of a "Polished Super Safety W/ Precut Rounded Trig" offered for sale at $99.99, illustrating the product and its market presentation Compl. ¶31, p. 9

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..., a cam..., and a safety selector adapted to... pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	When installed, the Super Safety is part of a forced reset trigger mechanism with a selector that provides for safe, standard, and forced reset modes of operation.	¶42	col. 7:5-8:44
whereupon in said standard semi-automatic position, rearward movement of the bolt carrier causes... said disconnector hook [to] catch said hammer hook,... at which time a user must manually release said trigger member to free said hammer from said disconnector...	The Super Safety operates in a standard semi-automatic mode where the disconnector catches the hammer, requiring the user to release the trigger to reset it for the next shot.	¶42, p. 22	col. 8:66-9:24
whereupon in a forced reset semi-automatic mode, said cam is in said second position, 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 without manually releasing said trigger member.	When in the forced reset mode, the Super Safety's cam forces the trigger to reset while the disconnector is prevented from catching the hammer, allowing the user to fire again without releasing the trigger. The complaint provides a diagram illustrating the disconnector hook being prevented from catching the hammer hook (Compl. ¶42, p. 23).	¶42, p. 23	col. 9:25-10:11

• Identified Points of Contention:
  • Scope Questions: Claim 15 is highly detailed, reciting a specific sequence of mechanical interactions for both standard and forced reset modes. A central question will be whether the accused "Super Safety" performs every step of both sequences as claimed. Any deviation in the operational logic could be a basis for a non-infringement argument.
  • Technical Questions: What evidence demonstrates that the accused safety selector performs the claimed function of "preventing the disconnector hook from catching said hammer hook"? The infringement analysis will likely require a detailed technical examination of how the selector and disconnector interact in the accused product versus the specific mechanism disclosed in the patent.

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
...an extended trigger member locking device, comprising: a locking member that is movable between a first position... and a second position...	The Super Safety is part of a forced reset trigger mechanism and functions as an extended trigger member locking device that moves between a locked and unlocked position.	¶56	col. 2:45-59
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 operates as a locking member with an upward extending portion (lever arm) that makes contact with the bolt carrier. The complaint's allegations and diagrams suggest this portion is designed to operate as the claimed deflectable part. A diagram shows this lever arm making actuating contact with the bolt carrier (Compl. ¶56, p. 31).	¶56, p. 31	col. 2:60-3:5

• Identified Points of Contention:
  • Scope Questions: The case may turn on the construction of "separately movable." Does this require a distinct mechanical pivot, as shown in the patent's embodiments (e.g., a hinge pin), or could it be read more broadly to cover a unitary piece designed to flex at a specific point? The defendant may argue its product uses a flexible, one-piece arm, not a "separately movable" hinged component.
  • Technical Questions: What is the specific structure of the accused locking member's upward extension? A key evidentiary question will be whether it comprises two portions-a "body" and a "deflectable portion"-that move relative to one another, or if it is a single, monolithic component.

V. Key Claim Terms for Construction

'247 Patent

• The Term: "forces said trigger member to the set position" (from Claim 15)
• Context and Importance: This term defines the core "forced reset" action. The nature of this "force" is critical to infringement. The dispute may center on whether the cam's interaction with the trigger in the accused product constitutes a direct, mechanical "forcing" as required by the claim, or if the reset occurs via a different mechanism.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's summary of the invention describes the action in general terms, such as the cam lobe "forces the trigger member towards the set position," which a party might argue does not require a specific type of physical contact '247 Patent, col. 3:60-62
  • Evidence for a Narrower Interpretation: The detailed description and figures show a direct mechanical interaction. The specification states, "the cam lobe 78 acts upon the cam follower 58 to pivot the trigger member 38 counter-clockwise," suggesting a direct physical push '247 Patent, col. 9:48-51 This supports a narrower construction requiring direct mechanical causation.

'784 Patent

• The Term: "separately movable relative to the body portion" (from Claim 1)
• Context and Importance: This term is the central novelty of the '784 patent, distinguishing it from prior art and other patents in the family. Practitioners may focus on this term because infringement will likely depend on whether the accused product's locking arm has a part that is "separately movable" from its main body, or if it is a single, flexible component.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that a single piece of material with a designed-in "living hinge" or a narrow flex point has a portion that is "separately movable" in function, even without a distinct mechanical joint.
  • Evidence for a Narrower Interpretation: The specification repeatedly refers to a "hinging structure," a "one-way hinge feature," and illustrates embodiments with a distinct pivot pin (pin 24) connecting the deflectable portion (22) to the body (26) '784 Patent, col. 2:62-63 '784 Patent, Fig. 2 This strongly supports a construction requiring a discrete, articulated joint.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Defendant encourages and instructs customers on how to install and use the "Super Safety" to create an infringing system Compl. ¶43 Compl. ¶57 Contributory infringement is based on allegations that Defendant sells key components, such as the "cam or cam lever arm," that are specially designed for infringing use and have no substantial non-infringing purpose Compl. ¶45 Compl. ¶59
• Willful Infringement: Willfulness is alleged for all five patents. The complaint asserts that Defendant has engaged in "egregious infringement behavior with knowledge of the... Patent" and that Defendant "has known or should have known" its actions constitute infringement, at least from the service of the complaint Compl. ¶46 Compl. ¶60 Compl. ¶74 Compl. ¶88 Compl. ¶102

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

1. A Structural Question of Equivalence: Does the accused "Super Safety" locking mechanism contain a "separately movable" and "deflectable portion" as claimed by the '784 patent? The case may depend on whether a single, flexible arm in the accused product can be considered equivalent to the hinged, multi-part structure described and claimed in the patent.
2. A Functional Question of Precision: Does the accused product's operation map precisely to the detailed, multi-step sequences recited in the claims of the '247 and '159 patents for both standard and forced-reset modes? Given the complexity of the claims, the infringement analysis will require a rigorous, step-by-step comparison, where any functional deviation could defeat the infringement allegation.
3. A Question of Patent Differentiation: The five asserted patents claim different, but overlapping, aspects of forced reset trigger technology. A central issue for the court will be to construe the claims of each patent distinctly and determine if the single accused product infringes the specific and unique limitations of all five patents, or only a subset.