ABC IP LLC v. TRG Ventures LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: TRG Ventures, LLC d/b/a Mission Ridge Range and Academy (Texas) and TRG Ventures, LP (Texas)
  • Plaintiff's Counsel: Fish & Richardson P.C.; Wood Herron & Evans LLP
• Case Identification: 2:26-cv-00201, E.D. Tex., 03/13/2026
• Venue Allegations: Plaintiffs allege venue is proper because Defendants reside in the district and have a regular and established place of business there, including a specific storefront location.
• Core Dispute: Plaintiffs allege that Defendants' "Partisan Disruptor" trigger assembly infringes four patents related to forced reset trigger mechanisms for semiautomatic firearms.
• Technical Context: The technology at issue involves firearm trigger mechanisms designed to be "forcibly reset" by the cycling of the firearm's action, which can enable a significantly faster rate of fire than standard semiautomatic triggers.
• Key Procedural History: The complaint states that Plaintiff ABC IP, LLC is the owner by assignment of the Asserted Patents and that Plaintiff Rare Breed Triggers, Inc. is the exclusive licensee. No other procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2017-09-29	U.S. Patent No. 10,514,223 Priority Date
2019-12-24	U.S. Patent No. 10,514,223 Issue Date
2022-01-10	U.S. Patent Nos. 11,724,003, 12,036,336, and 12,274,807 Priority Date
2023-08-15	U.S. Patent No. 11,724,003 Issue Date
2024-07-16	U.S. Patent No. 12,036,336 Issue Date
2025-04-15	U.S. Patent No. 12,274,807 Issue Date
2026-03-13	Complaint Filing Date

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

U.S. Patent No. 10,514,223 - "FIREARM TRIGGER MECHANISM" (Issued Dec. 24, 2019)

The Invention Explained

• Problem Addressed: The patent's background section notes that in a standard semiautomatic firearm, the rate of fire is limited because a user is "not typically able to release the trigger rapidly enough" for the trigger mechanism to reset before the firearm's action has completed its cycle '223 Patent, col. 1:26-32 This limitation prevents shooters who desire a higher rate of fire from achieving it with a standard trigger mechanism '223 Patent, col. 1:36-38
• The Patented Solution: The invention is a trigger mechanism where the hammer, as it is pushed back by the reciprocating bolt carrier, makes contact with the trigger member and mechanically forces it back to the reset position '223 Patent, abstract '223 Patent, col. 2:40-44 A separate "locking bar" then prevents the trigger from being pulled again until the bolt carrier has returned to a "substantially in-battery position," which is intended to prevent "hammer follow" (the hammer falling before the action is safely closed) '223 Patent, abstract '223 Patent, col. 2:44-48 This process automates the trigger reset, allowing the user to fire again as soon as the action is closed.
• Technical Importance: The technology provides a "drop-in" mechanical solution that increases the potential rate of fire for common firearm platforms like the AR-15 without requiring complex modifications to the firearm itself '223 Patent, col. 2:30-39

Key Claims at a Glance

• The complaint asserts independent Claim 4 Compl. ¶33
• The essential elements of Claim 4 include:
  • A housing for receiving hammer and trigger assembly pins.
  • A hammer with a sear notch, pivotally mounted in the housing.
  • A trigger member with a sear, pivotally mounted in the housing.
  • The trigger member has a surface that is contacted by the hammer when the bolt carrier cycles, with this contact "causing the trigger member to be forced to the set position."
  • A locking bar, pivotally mounted and spring-biased, that "mechanically blocks" the trigger member from moving.
  • The locking bar is movable to a second, unblocking position when contacted by the bolt carrier as it reaches a "substantially in-battery position," allowing the trigger to be moved by an external force.
• The complaint reserves the right to assert additional claims Compl. ¶33

U.S. Patent No. 11,724,003 - "FIREARM TRIGGER MECHANISM" (Issued Aug. 15, 2023)

The Invention Explained

• Problem Addressed: While forced reset triggers can increase the rate of fire, there is a desire for a single trigger mechanism that can operate in both a standard semiautomatic mode and an enhanced forced-reset mode '003 Patent, col. 2:19-22 The complaint alleges this patent family adds the feature of selectable operating modes to the forced-reset concept Compl. ¶23
• The Patented Solution: The patent describes a trigger mechanism with a three-position safety selector that allows the user to choose between "safe, standard semi-automatic, and forced reset semi-automatic positions" '003 Patent, abstract In the standard mode, a disconnector functions conventionally to catch the hammer, requiring the user to manually release the trigger to reset it. In the forced reset mode, the safety selector physically prevents the disconnector from engaging the hammer, allowing the forced-reset functionality (where the hammer resets the trigger) to operate without interference '003 Patent, abstract
• Technical Importance: This invention provides a user-selectable, multi-mode functionality within a single "drop-in" trigger module, offering both the conventional operation of a standard trigger and the rapid-fire capability of a forced reset trigger '003 Patent, col. 2:32-39

Key Claims at a Glance

• The complaint asserts independent Claim 4 Compl. ¶47
• The essential elements of Claim 4 include:
  • A housing, hammer, trigger member, disconnector, and locking member, which function together in a forced reset capacity similar to the '223 patent.
  • A "safety selector" adapted to pivot between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • A "whereupon" clause for the standard semi-automatic position, describing that the disconnector hook catches the hammer hook, and the user "must manually release said trigger member" to fire again.
  • A "whereupon" clause for the forced reset position, describing that the cycling bolt carrier forces the trigger to its set position, the safety selector "preventing said disconnector hook from catching said hammer hook," and the user can subsequently fire "without manually releasing said trigger member."
• The complaint reserves the right to assert additional claims Compl. ¶47

Multi-Patent Capsule: U.S. Patent No. 12,036,336 (Issued July 16, 2024)

• Patent Identification: U.S. Patent No. 12,036,336, "FIREARM TRIGGER MECHANISM," issued July 16, 2024 Compl. ¶12
• Technology Synopsis: The complaint groups this patent with the '003 Patent as describing a similar selectable-mode device Compl. ¶23 The patent abstract confirms this, detailing a trigger mechanism with a "three position" safety selector that enables safe, standard semi-automatic, and forced reset semi-automatic modes of operation by controlling the interaction of the disconnector '336 Patent, abstract
• Asserted Claims: The complaint asserts independent Claim 3 Compl. ¶61
• Accused Features: The complaint accuses the "Partisan Disruptor" and its three-position safety selector, which allegedly allows operation in both a standard semi-automatic mode and a forced reset semi-automatic mode Compl. ¶28 Compl. ¶63

Multi-Patent Capsule: U.S. Patent No. 12,274,807 (Issued April 15, 2025)

• Patent Identification: U.S. Patent No. 12,274,807, "FIREARM TRIGGER MECHANISM," issued April 15, 2025 Compl. ¶13
• Technology Synopsis: The complaint alleges this patent also covers a selectable-mode trigger mechanism Compl. ¶23 The patent's abstract describes a trigger mechanism with a three-position safety selector that allows a user to select between safe, standard, and forced reset semi-automatic modes, functionally similar to the '003 and '336 patents '807 Patent, abstract
• Asserted Claims: The complaint asserts independent Claim 1 Compl. ¶75
• Accused Features: The allegations target the "Partisan Disruptor's" selectable-mode functionality, enabled by its three-position safety selector, which is alleged to practice the claimed invention Compl. ¶28 Compl. ¶77

III. The Accused Instrumentality

Product Identification

• The accused product is the "Partisan Disruptor" trigger assembly Compl. ¶25

Functionality and Market Context

• The complaint alleges the Partisan Disruptor is a "forced reset trigger assembly" designed for installation in AR-15 pattern firearms Compl. ¶25 A key feature is a three-position safety selector that allows the user to switch between safe, standard semiautomatic, and forced reset modes Compl. ¶28 In the forced reset mode, the cycling of the firearm's action "causes hammer contact with the trigger member to forcefully reset the hammer and trigger member," while a "locking bar/member" prevents firing until the bolt carrier is in battery Compl. ¶29 Defendants are alleged to sell and offer for sale this device through their website Compl. ¶26 The complaint includes a screenshot from the Defendant's website describing the product as an "assisted reset trigger" with "Safe, Semi-Automatic, and Enhanced Semi-Automatic modes" Compl. p. 6

IV. Analysis of Infringement Allegations

10,514,223 Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins;	The Infringing Device includes a housing with transversely aligned openings for the hammer and trigger assembly pins.	¶35, p. 8	col. 3:36-44
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The Infringing Device includes a hammer with a sear notch mounted to pivot in the housing. The complaint provides a plaintiff-generated rendering of the accused hammer (Compl. p. 9).	¶35, p. 9	col. 4:24-27
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions,	The Infringing Device has a trigger member with a sear mounted to pivot in the housing.	¶35, p. 11	col. 3:51-64
the trigger member having a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position;	The trigger member has a surface that is contacted by the hammer during rearward pivoting, which forces the trigger to the set position.	¶35, p. 12	col. 5:32-38
a locking bar pivotally mounted in the housing and spring biased toward a first position in which the locking bar mechanically blocks the trigger member from moving to the released position,	The Infringing Device includes a pivotally mounted locking bar that is spring biased to a first position where it mechanically blocks the trigger member.	¶35, p. 13	col. 4:61-64
and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved by an external force to the released position.	The locking bar is movable to a second position when contacted by the bolt carrier as it reaches an in-battery position, allowing the trigger to be pulled.	¶35, p. 13	col. 5:1-11

• Identified Points of Contention:
  • Scope Questions: A potential point of contention may be the term "substantially in-battery position." The analysis will question what degree of bolt closure meets this standard and whether the accused device's locking bar disengages at a point in the cycle that falls within the scope of this term as defined by the patent.
  • Technical Questions: The analysis may focus on whether the accused device's "locking bar" functions to "mechanically block" the trigger member in the manner claimed. The specific nature of the physical interference between the locking bar and the trigger member in the accused device will be compared against the patent's description and figures.

11,724,003 Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a safety selector adapted to be mounted in a fire control mechanism pocket of a receiver to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Infringing Device includes a safety selector that pivots between safe, standard semi-automatic, and forced reset semi-automatic positions. The complaint includes a photograph of the accused safety selector (Compl. p. 25).	¶49, p. 25	col. 4:3-9
whereupon in said standard semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook catches said hammer hook, at which time a user must manually release said trigger member...	In the standard semi-automatic position, rearward movement of the bolt carrier allegedly causes the hammer to pivot and the disconnector hook to catch the hammer hook.	¶49, p. 25	col. 3:4-11
whereupon in said forced reset semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer causing said trigger member to be forced to said set position,	When in the forced reset position, rearward movement of the bolt carrier allegedly causes the hammer to pivot, forcing the trigger to the set position.	¶49, p. 26	col. 3:11-16
said safety selector preventing said disconnector hook from catching said hammer hook,	The safety selector allegedly prevents the disconnector hook from catching the hammer hook when in the forced reset position.	¶49, p. 27	col. 3:16-19
and thereafter when the bolt carrier reaches the substantially in-battery position the user can pull said trigger member to fire the firearm without manually releasing said trigger member.	When the bolt carrier is in battery, the user can allegedly pull the trigger to fire without first having to manually release it.	¶49, p. 27	col. 3:19-24

• Identified Points of Contention:
  • Scope Questions: The interpretation of the functional language "preventing said disconnector hook from catching said hammer hook" will be critical. The question is whether the accused safety selector achieves this prevention through the same mechanism or principle of operation described and claimed in the patent.
  • Technical Questions: An evidentiary question will be how, precisely, the accused safety selector interacts with the disconnector. The complaint alleges the selector "preventing the disconnector hook from catching the hammer hook" Compl. ¶31, but the case may turn on expert testimony dissecting the specific mechanical pathway by which this prevention occurs in the accused device.

V. Key Claim Terms for Construction

• The Term: "forced to the set position" (asserted in both lead patents)

  • Context and Importance: This phrase describes the core inventive concept of using the firearm's own action to reset the trigger. Practitioners may focus on this term because the nature of the "forcing" action-its timing, mechanism, and ability to overcome user pressure-is fundamental to how the invention operates and distinguishes it from a standard trigger.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language states that "contact causing the trigger member to be forced to the set position" '223 Patent, claim 4 This suggests that any contact from the hammer that results in the trigger reaching its set position could fall within the claim's scope.
    • Evidence for a Narrower Interpretation: The specification describes "mechanical interference or contact between a rear surface 74 of the hammer 18... and a contact surface 30 of the trigger member 26 forces the trigger to pivot" '223 Patent, col. 5:32-37 A party could argue this language, tied to specific surfaces shown in Figure 5, limits the term to the particular geometry and interaction disclosed in the embodiments.

• The Term: "safety selector preventing said disconnector hook from catching said hammer hook" (asserted in '003 patent)

  • Context and Importance: This limitation defines the unique function of the safety selector in the "forced reset" mode, which is central to the selectable-mode patents. The dispute will likely center on whether "preventing" requires direct physical blocking by the selector itself or can encompass indirect actions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the functional term "preventing" without specifying the mechanism. A party could argue that any action by the safety selector that results in the disconnector being unable to catch the hammer-whether direct or indirect-satisfies this limitation.
    • Evidence for a Narrower Interpretation: The detailed description states that in the forced reset position, "a narrow semi-circular portion 116... prevents the disconnector 60 from pivoting with the trigger member 38 thus preventing the disconnector hook 64 from catching the hammer hook 53" '003 Patent, col. 9:22-28 A party may argue this language requires the safety selector to directly impede the pivotal movement of the disconnector, limiting the claim to that specific mechanical interaction.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating Defendants provide promotional materials and instructions on their website that encourage customers to install and use the accused device in an infringing manner in an AR-15 firearm Compl. ¶36 Compl. ¶50 Compl. ¶64 Compl. ¶78 The complaint also alleges contributory infringement, asserting that components of the accused device are "specially designed and adapted to be used in a fire control unit to forcibly reset a trigger mechanism" and are not suitable for substantial noninfringing use Compl. ¶38 Compl. ¶52 Compl. ¶66 Compl. ¶80
• Willful Infringement: The complaint alleges that Defendants "have known or should have known" their actions constituted infringement and have engaged in "egregious infringement behavior" Compl. ¶39 Compl. ¶53 Compl. ¶67 Compl. ¶81 The allegations are made "on information and belief" and appear to be based on post-suit knowledge at a minimum, with an assertion of pre-suit knowledge.

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

1. A core issue will be one of functional interpretation: How will the court construe "forced to the set position"? The case may turn on whether any hammer-induced reset is sufficient for infringement, or if the claims require the specific mechanical interaction and geometry shown in the patent's embodiments.
2. A central question for the selectable-mode patents ('003, '336, '807) will be one of mechanical operation: Does the accused safety selector's mechanism for disabling the disconnector operate in the same way as the claimed method of "preventing said disconnector hook from catching said hammer hook"? This will likely devolve into a technical dispute between experts over the precise interaction of components in the accused device.
3. The analysis will also raise an issue of temporal scope: What is the proper construction of "substantially in-battery position"? The determination of infringement for the locking bar limitation will depend on the factual evidence of when, during the bolt carrier's forward travel, the accused device's locking mechanism disengages relative to the definition established during claim construction.