Rare Breed Triggers Inc v. Dairyland Defense Solutions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware) and Rare Breed Triggers, Inc. (Texas)
  • Defendant: Dairyland Defense Solutions LLC (Wisconsin) and Gaven L. Poczekaj, Sr. (Wisconsin)
  • Plaintiff's Counsel: Fish & Richardson P.C.; Gillam & Smith, LLP; Wood Herron & Evans LLP
• Case Identification: 4:26-cv-00374, E.D. Tex., 05/26/2026
• Venue Allegations: Venue is alleged to be proper as Defendants reside in or have committed acts of infringement and have a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendants' "Dairyland Defender" trigger assembly infringes five U.S. patents related to "forced reset" firearm trigger mechanisms that increase the rate of semi-automatic fire.
• Technical Context: The technology at issue involves mechanical trigger systems for AR-15-style firearms designed to use the force of the firearm's cycling action to reset the trigger, enabling a faster rate of fire than standard semi-automatic mechanisms.
• Key Procedural History: The case is part of the In Re: Rare Breed Triggers Patent Litigation Multi-District Litigation (MDL 3176). The complaint alleges Defendants had pre-suit knowledge of Plaintiffs' patent rights, referencing a prior court hearing involving the Plaintiffs.

Case Timeline

Date	Event
2017-09-29	'223 Patent Priority Date
2019-12-24	'223 Patent Issue Date
2022-01-10	Priority Date for '003, '336, '807, '403 Patents
2023-08-15	'003 Patent Issue Date
2024-07-16	'336 Patent Issue Date
2024-12-09	Accused Product Pre-order Date Mentioned
2025-04-15	'807 Patent Issue Date
2026-05-26	'403 Patent Issue Date
2026-05-26	Complaint Filing Date

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

U.S. Patent No. 10,514,223 - Firearm Trigger Mechanism

• Issued: December 24, 2019

The Invention Explained

• Problem Addressed: In a standard semi-automatic firearm, a disconnector holds the hammer after a shot is fired until the user manually resets the trigger Compl. ¶20 '223 Patent, col. 1:25-35 This process is typically slower than the mechanical cycling of the firearm's action, which limits the potential rate of fire '223 Patent, col. 1:29-32
• The Patented Solution: The invention is a trigger mechanism where the cycling of the firearm's bolt carrier causes the hammer to make contact with the trigger member, mechanically forcing the trigger to its reset position Compl. ¶22 '223 Patent, abstract A "locking bar" is included to block the trigger from being pulled again until the bolt carrier has returned to a "substantially in-battery position," which is intended to prevent malfunctions such as "hammer follow" '223 Patent, abstract '223 Patent, col. 5:54-68
• Technical Importance: The invention provides a mechanical, "drop-in" solution for increasing the rate of fire of common firearms like the AR-15, without requiring complex electronics or user techniques like "bump firing" '223 Patent, col. 2:30-41

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 4 Compl. ¶33
• The essential elements of independent claim 4 include:
  • A housing with openings for hammer and trigger pins.
  • A hammer with a sear notch, pivotally mounted in the housing.
  • A trigger member with a sear, also pivotally mounted, and having a surface to be contacted by the hammer when the hammer is displaced by the bolt carrier.
  • The contact causes the trigger member to be "forced to the set position."
  • A "locking bar" pivotally mounted in the housing, which is spring-biased to a first position where it blocks the trigger member.
  • The locking bar is movable to a second, non-blocking position when contacted by the bolt carrier as it reaches a "substantially in-battery position," allowing the trigger to be pulled.
• The complaint reserves the right to assert other claims Compl. ¶33

U.S. Patent No. 11,724,003 - Firearm Trigger Mechanism

• Issued: August 15, 2023

The Invention Explained

• Problem Addressed: The patent background notes a desire for "further improvement in forced reset triggers" beyond existing designs '003 Patent, col. 2:21-22
• The Patented Solution: This invention builds upon the forced-reset concept by adding a three-position safety selector that allows the user to choose between "safe," "standard semi-automatic," and "forced reset semi-automatic" modes Compl. ¶23 '003 Patent, abstract In the forced reset mode, the selector is configured to interact with the disconnector to prevent it from catching the hammer, thereby enabling the forced reset functionality while disabling the standard disconnector operation '003 Patent, abstract '003 Patent, col. 10:5-10
• Technical Importance: This design offers the operator the flexibility to switch between a conventional semi-automatic trigger operation and a rapid-fire forced-reset capability within a single, integrated mechanism '003 Patent, col. 1:35-38

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 4 Compl. ¶47
• The essential elements of independent claim 4 are extensive and include all the core components of a forced reset trigger (housing, hammer, trigger member, locking member), plus:
  • A disconnector with a hook for engaging the hammer.
  • A safety selector adapted to pivot between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • Functional limitations describing the different behavior in both the "standard" mode (where the user must manually release the trigger to reset the disconnector) and the "forced reset" mode (where the user can fire again without manually releasing the trigger).
• The complaint reserves the right to assert other claims Compl. ¶47

U.S. Patent No. 12,036,336 - Firearm Trigger Mechanism

• Issued: July 16, 2024 Compl. ¶12
• Technology Synopsis: This patent appears to be a continuation of the '003 patent, describing a similar trigger mechanism with a three-position safety selector for safe, standard semi-automatic, and forced reset semi-automatic modes '336 Patent, abstract The claims are directed to a trigger mechanism with these features.
• Asserted Claims: At least independent Claim 3 is asserted Compl. ¶61
• Accused Features: The "Dairyland Defender" is accused of infringing by incorporating a trigger mechanism with a selectable forced reset mode Compl. ¶¶61, 63

U.S. Patent No. 12,274,807 - Firearm Trigger Mechanism

• Issued: April 15, 2025 Compl. ¶13
• Technology Synopsis: This patent also appears to cover the same technological ground as the '003 and '336 patents. It claims a firearm trigger mechanism with a hammer, trigger member, disconnector, locking member, and a three-position safety selector enabling standard and forced reset semi-automatic modes '807 Patent, abstract
• Asserted Claims: At least independent Claim 1 is asserted Compl. ¶74
• Accused Features: The "Dairyland Defender" is accused of infringing by embodying the claimed multi-mode trigger mechanism Compl. ¶¶74, 76

U.S. Patent No. 12,636,403 - Firearm Trigger Mechanism

• Issued: May 26, 2026 Compl. ¶14
• Technology Synopsis: This patent claims a "forced reset trigger mechanism" comprising a hammer, disconnector, trigger member, and a safety selector movable between a "standard semi-automatic position" and a "forced reset semi-automatic position." It describes the distinct operational outcomes in each mode. '403 Patent, abstract
• Asserted Claims: At least independent Claim 38 is asserted Compl. ¶88
• Accused Features: The "Dairyland Defender," when used as directed, is alleged to be part of a "forced reset" trigger mechanism that infringes the claims Compl. ¶¶88, 90

III. The Accused Instrumentality

Product Identification

• The "Dairyland Defender," which the complaint describes as a trigger assembly that includes a three-position safety selector Compl. ¶25

Functionality and Market Context

• The complaint alleges the Dairyland Defender is designed for AR-15 pattern firearms and can operate in a "disconnector mode," similar to a standard trigger, or a "forced reset" mode Compl. ¶27 In the "forced reset" mode, the cycling of the firearm's action is alleged to cause hammer contact that mechanically resets the trigger and hammer Compl. ¶28 The product was allegedly sold via the defendants' website and promoted on Facebook Compl. ¶26 An image provided in the complaint shows a photograph of the accused trigger assembly components Compl. ¶26, p. 6

IV. Analysis of Infringement Allegations

'223 Patent 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 Dairyland Defender includes a housing with transversely aligned pairs of openings for receiving hammer and trigger assembly pins.	¶35, p. 9	col. 3:35-43
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The Dairyland Defender includes a hammer with a sear notch and is mounted in the housing to pivot on a transverse axis.	¶35, p. 9	col. 3:46-50
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions,	The Dairyland Defender includes a trigger member with a sear and that is mounted in the housing to pivot on a transverse axis between set and released positions.	¶35, p. 10	col. 3:51-54
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 trigger member has a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled.	¶35, p. 10	col. 4:1-11
the contact causing the trigger member to be forced to the set position;	The contact causes the trigger member to be mechanically moved to the set position.	¶35, p. 11	col. 5:31-36
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 Dairyland Defender includes a locking bar that is pivotally mounted in the housing and is spring biased toward a first position to mechanically block the trigger.	¶35, p. 11	col. 4:61-64; 5:1-9
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...	The locking bar is movable against the spring bias to a second position when contacted by the bolt carrier as it reaches a substantially in-battery position.	¶35, p. 11	col. 5:54-63

• Identified Points of Contention:
  • Technical Question: The core of the infringement analysis will likely depend on the precise mechanical operation of the accused device. A key question is whether the interaction between the hammer and trigger in the Dairyland Defender performs the function of forcing the trigger to a "set position" in the manner required by the claim. The complaint provides an annotated image showing the alleged "Trigger Surface" and "Hammer Surface" that make contact (Compl. ¶35, p. 10).
  • Scope Question: The claim requires a "locking bar" that is contacted by the "bolt carrier" to move it into a non-blocking position. The court may need to determine whether the accused product's corresponding "locking bar/member," as depicted in the complaint (Compl. ¶35, p. 11), operates in the specific manner recited, particularly regarding the timing and mechanism of its interaction with the bolt carrier.

'003 Patent 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 Dairyland Defender includes a safety selector mounted in the fire control mechanism pocket of a receiver to pivot between safe, standard semi-automatic, and "forced reset" semi-automatic positions.	¶49, p. 16	col. 9:11-15
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...so that the user can pull said trigger member to fire the firearm, and	When in the standard semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of the hammer such that the disconnector hook catches the hammer hook, at which time a user must manually release the trigger member to free the hammer from the disconnector to permit the hammer and trigger member to pivot to the set positions so that the user can pull the trigger member to fire the firearm.	¶49, p. 17	col. 10:36-50
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, said safety selector preventing said disconnector hook from catching said hammer hook, 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 in the "forced reset" semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of the hammer, causing the trigger member to be mechanically moved to the set position. The safety selector prevents the disconnector hook from catching the hammer hook. Thereafter, when the bolt carrier reaches the substantially in-battery position, the user can pull the trigger member to fire the firearm without manually releasing the trigger member. An annotated image in the complaint shows the alleged disconnector component (Compl. ¶49, p. 16).	¶49, p. 17	col. 10:5-26

• Identified Points of Contention:
  • Technical Question: The infringement allegation for the '003 patent family hinges on the dual-mode functionality. A central question for the court will be whether the Dairyland Defender's safety selector and disconnector interact in the specific manner claimed to create two distinct modes of operation. Evidence will be required to show that in the "forced reset" mode, the selector physically "prevent[s] said disconnector hook from catching said hammer hook," as recited in the claim.
  • Scope Question: The claims describe the operational outcomes in both standard and forced-reset modes. The dispute may focus on whether the accused product's "standard" mode is functionally identical to the claimed mode, which requires a user to "manually release said trigger member to free said hammer from said disconnector."

V. Key Claim Terms for Construction

• "forced to the set position" ('223 Claim 4; '003 Claim 4)

  • Context and Importance: This phrase is the technological core of the "forced reset" invention. Its construction is critical because it defines the required action for resetting the trigger. A broad definition might cover any mechanism where the firearm's cycle assists in the reset, while a narrow one could require a specific type and direction of force.
  • Intrinsic Evidence for a Broader Interpretation: The patent specification describes the general concept of the invention as providing a mechanism where "the normal resetting of the hammer, as the bolt or bolt carrier is cycled, causes the trigger to be forcibly reset" '223 Patent, col. 2:38-41
  • Intrinsic Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific embodiment where "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... to its reset position" '223 Patent, col. 5:31-36 This could support an interpretation requiring direct contact and force from the hammer onto the trigger.

• "locking bar" ('223 Claim 4) / "locking member" ('003 Claim 4)

  • Context and Importance: This element is the primary safety feature preventing the firearm from firing out of battery. Its definition will determine whether the accused component, which performs a similar safety function, falls within the claim's scope. Practitioners may focus on this term because the structural and functional details of safety mechanisms are often points of distinction.
  • Intrinsic Evidence for a Broader Interpretation: The claims define the element by its function: it "mechanically blocks the trigger member from moving to the released position" '223 Patent, Claim 4 This functional language may support a broader scope.
  • Intrinsic Evidence for a Narrower Interpretation: The specification discloses a specific "pivotally mounted" bar that is "movable against the spring bias... when contacted by the bolt carrier" '223 Patent, Claim 4 '223 Patent, Fig. 3 This could be used to argue for a narrower construction limited to a pivoting structure with a specific activation mechanism.

• "substantially in-battery position" ('223 Claim 4; '003 Claim 4)

  • Context and Importance: This term of degree defines the precise timing of when the trigger is unblocked and can be pulled again. Its construction is critical for both infringement and safety, as it dictates the point in the firearm's cycle at which a subsequent shot is permitted.
  • Intrinsic Evidence for a Broader Interpretation: The specification uses phrases like "at or near its in-battery position," suggesting some tolerance is contemplated '223 Patent, col. 5:1-3
  • Intrinsic Evidence for a Narrower Interpretation: The patent explicitly states a purpose of the locking bar is to prevent hammer release "before the bolt is completely locked and in-battery" '223 Patent, col. 5:65-68 This language could support a stricter interpretation requiring the bolt to be fully secured.

VI. Other Allegations

• Indirect Infringement: The complaint alleges Defendants induced infringement by "encouraging, advertising, promoting, and instructing others to use and/or how to use the Dairyland Defender" Compl. ¶36 It further alleges contributory infringement on the basis that the Dairyland Defender is a material part of the invention, is specially designed for use in an infringing manner, and is not a staple article suitable for substantial noninfringing use Compl. ¶38
• Willful Infringement: Willfulness is alleged based on Defendants' purported pre-suit knowledge of Plaintiffs' patent rights Compl. ¶30 The complaint provides a screenshot of an email allegedly from Defendant Gaven Poczekaj which explicitly mentions "Rare breed," a recent "court hearing," and states, "[d]ue to this, we are no longer allowed to sell the Dairyland Defender" Compl. ¶30, p. 7 This email is presented as direct evidence of knowledge.

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

• A core issue will be one of claim construction and technical infringement: does the accused "Dairyland Defender" operate with the precise mechanical sequences recited in the patents? This will involve detailed analysis of whether the accused product's "locking member" and mode-switching "safety selector" are structurally and functionally equivalent to the claimed elements, or if they represent a different, non-infringing technical approach to achieving a similar result.
• A second key question will be one of intent and damages: given the complaint's evidence of an email explicitly referencing the Plaintiffs and a court ruling Compl. ¶30, the focus may quickly shift to willfulness. Can Defendants establish a good-faith belief of non-infringement or invalidity, or will the central dispute concern the extent of damages, including the possibility of enhancement for willful infringement?
• Finally, the case raises a question of infringement liability for component sales: since Defendants sell a trigger assembly rather than a complete firearm, the viability of the claims for direct infringement may be contested, elevating the importance of Plaintiffs' ability to prove the elements of induced and contributory infringement.