Rare Breed Triggers Inc v. DNT LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware), Rare Breed Triggers, Inc. (Texas), and RBTM LLC (Wyoming)
  • Defendant: DNT LLC, d/b/a DEEZ NUTZ TACTICAL (Idaho), and Zach Morrow (Idaho)
  • Plaintiff's Counsel: Fish & Richardson P.C.
• Case Identification: 4:26-cv-00377, E.D. Tex., 05/27/2026
• Venue Allegations: Plaintiffs allege venue is proper because Defendants reside in and/or have a regular and established place of business in the district.
• Core Dispute: Plaintiffs allege that Defendants' firearm trigger mechanisms infringe ten U.S. patents related to "forced reset" trigger technology, which uses a firearm's cycling action to mechanically reset the trigger.
• Technical Context: The technology at issue involves aftermarket firearm triggers designed to increase the potential rate of fire for semi-automatic firearms, a commercially significant segment of the firearms accessory market.
• Key Procedural History: This case is part of a multi-district litigation, In Re: Rare Breed Triggers Patent Litigation (MDL 3176), and the operative pleading is a Sixth Amended Complaint. Plaintiffs allege sending a cease-and-desist letter to Defendants on March 31, 2025, providing pre-suit notice for at least one of the asserted patents.

Case Timeline

Date	Event
2003-04-25	'723 Patent Priority Date
2008-07-15	U.S. Patent No. 7,398,723 Issue Date
2017-09-29	'223 Patent Priority Date
2019-12-24	U.S. Patent No. 10,514,223 Issue Date
2020-01-01	Plaintiff begins using FRT mark (at least as early as)
2021-11-05	'784 Patent Priority Date
2022-01-10	'003, '336, '807, and '403 Patents Priority Date
2022-09-08	'247 and '159 Patents Priority Date
2023-08-15	U.S. Patent No. 11,724,003 Issue Date
2023-12-04	'538 Patent Priority Date
2024-07-09	U.S. Patent No. 12,031,784 Issue Date
2024-07-16	U.S. Patent Nos. 12,038,247 & 12,036,336 Issue Date
2024-08-05	Accused "Super Safety" product offered for sale (at least as of)
2025-03-31	Cease and desist letter sent by Plaintiffs to Defendants
2025-04-15	U.S. Patent No. 12,274,807 Issue Date
2026-01-20	U.S. Patent No. 12,529,538 Issue Date
2026-03-17	U.S. Patent No. 12,578,159 Issue Date
2026-05-26	U.S. Patent No. 12,636,403 Issue Date
2026-05-27	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 Compl. ¶12

The Invention Explained

• Problem Addressed: In a standard semi-automatic firearm, the trigger must be manually released by the user to reset the firing mechanism, a process which limits the potential rate of fire Compl. ¶28 '247 Patent, col. 1:24-40 The disconnector component prevents the firearm from firing multiple rounds on a single pull but also necessitates this manual trigger release and reset sequence Compl. ¶28
• The Patented Solution: The invention is a trigger mechanism, termed a "forced reset," that uses the cycling of the firearm's action to mechanically force the trigger back to its reset position Compl. ¶29 It employs a selectable cam that, in one mode, interacts with the trigger to accelerate the firing sequence, obviating the need for the user to manually release the trigger to achieve a reset Compl. ¶30 '247 Patent, abstract The patent describes a mechanism with both a "standard semi-automatic mode" and a "forced reset semi-automatic mode" '247 Patent, col. 2:40-54
• Technical Importance: This approach allows for a significantly increased rate of fire in a semi-automatic platform, mimicking the performance of fully automatic firearms without, as alleged, converting the firearm to be legally defined as such Compl. ¶30

Key Claims at a Glance

• The complaint asserts one or more claims including independent claim 15 Compl. ¶65
• Essential elements of Claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam with a cam lobe.
  • The cam is movable between a first position and a second position.
  • In the second position, the cam lobe "forces said trigger member towards said set position."
  • The mechanism operates in a "standard semi-automatic mode" where the cam is in the first position, the disconnector catches the hammer, and the user must manually release the trigger to fire again.
  • The mechanism also operates in a "forced reset semi-automatic mode" where the cam is in the second position, the disconnector is prevented from catching the hammer, and the user can fire again once the bolt is in battery without manually releasing the trigger.
• The complaint reserves the right to assert other claims Compl. ¶65

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

• Issued: July 9, 2024 Compl. ¶13

The Invention Explained

• Problem Addressed: The patent background explains that prior forced reset trigger designs have "geometric limitations" that make them incompatible with certain firearm platforms (e.g., AR-10 style rifles) which have different dimensions than the common AR-15 platform '784 Patent, col. 1:22-30 Compl. ¶31 A locking member designed for one platform may physically interfere with the bolt carrier of another platform during its cycle of operation '784 Patent, col. 1:39-44
• The Patented Solution: The invention discloses a locking device with a "deflectable extension" that is "separately movable" from its main body '784 Patent, abstract This allows the extension to be actuated by the bolt carrier to unlock the trigger, but also to fold or deflect out of the way to avoid interfering with other parts of the carrier as it moves, thereby accommodating different firearm geometries Compl. ¶31 '784 Patent, col. 2:5-13
• Technical Importance: This innovation expands the applicability of forced reset technology to a wider variety of semi-automatic firearm designs beyond the standard AR-15 Compl. ¶31

Key Claims at a Glance

• The complaint asserts one or more claims including independent claim 1 Compl. ¶81
• 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 position (locks trigger) and a second position (unlocked).
  • The locking member has an upward extension to make "actuating contact" with the bolt carrier, which causes the member to move from the first to the second position.
  • The locking member has a "body portion" that is movably supported.
  • 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 reserves the right to assert other claims Compl. ¶81

U.S. Patent No. 12,529,538 - "Safety Mechanism For Firearm"

• Issued: January 20, 2026 Compl. ¶14

Technology Synopsis

The patent describes a safety mechanism for a firearm that includes a cam selector, a lever, and a trigger Compl. ¶32 The cam selector provides three modes of operation by using multiple recesses that interact with the trigger tail; in the third mode, the cam selector is configured to prevent the trigger from being pulled Compl. ¶32

• Asserted Claims: The complaint asserts one or more claims including independent claim 1 Compl. ¶112
• Accused Features: The "Super Safety" product is accused of infringing the '538 Patent Compl. ¶112

U.S. Patent No. 12,578,159 - "Firearm Trigger Mechanism"

• Issued: March 17, 2026 Compl. ¶15

Technology Synopsis

The patent discloses a device for accelerating the firing sequence of a semi-automatic firearm by using a cam that is rotated by the cycling of the action Compl. ¶30 The mechanism is selectable between a "standard semiautomatic mode" and a "forced reset" mode, which causes the trigger to reset and prevents the trigger from being pulled again until the action is in battery Compl. ¶30

• Asserted Claims: The complaint asserts one or more claims including independent claim 1 Compl. ¶126
• Accused Features: The "Super Safety," "ARC-Fire," and "Super Selector" products are accused of infringing the '159 Patent Compl. ¶126

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

• Issued: December 24, 2019 Compl. ¶16

Technology Synopsis

The patent describes a device where the cycling of the firearm's action causes the hammer to contact the trigger member, which mechanically resets both the hammer and trigger Compl. ¶33 A locking bar is included to prevent the user from pulling the trigger again until the bolt carrier has returned to its in-battery position '223 Patent, abstract Compl. ¶33

• Asserted Claims: The complaint asserts one or more claims including independent claim 4 Compl. ¶142
• Accused Features: The "Disruptor" product is accused of infringing the '223 Patent Compl. ¶142

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

• Issued: August 15, 2023 Compl. ¶17

Technology Synopsis

The patent describes a device that operates similarly to other asserted patents, with the additional feature that it can be selected to operate in two distinct modes: a standard disconnector semiautomatic mode and a "forced reset" semiautomatic mode Compl. ¶34

• Asserted Claims: The complaint asserts one or more claims including independent claim 4 Compl. ¶157
• Accused Features: The "Disruptor" product is accused of infringing the '003 Patent Compl. ¶157

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

• Issued: July 16, 2024 Compl. ¶18

Technology Synopsis

This patent is described as being for a "similarly operating device" with selectable standard disconnector and "forced reset" semiautomatic modes Compl. ¶34

• Asserted Claims: The complaint asserts one or more claims including independent claim 3 Compl. ¶172
• Accused Features: The "Disruptor" product is accused of infringing the '336 Patent Compl. ¶172

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

• Issued: April 15, 2025 Compl. ¶19

Technology Synopsis

This patent is described as being for a "similarly operating device" with selectable standard disconnector and "forced reset" semiautomatic modes Compl. ¶34

• Asserted Claims: The complaint asserts one or more claims including independent claim 1 Compl. ¶187
• Accused Features: The "Disruptor" product is accused of infringing the '807 Patent Compl. ¶187

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

• Issued: May 26, 2026 Compl. ¶20

Technology Synopsis

This patent is described as being for a "similarly operating device" with selectable standard disconnector and "forced reset" semiautomatic modes Compl. ¶34

• Asserted Claims: The complaint asserts one or more claims including independent claim 38 Compl. ¶202
• Accused Features: The "Super Safety," "ARC-Fire," "Super Selector," and "Disruptor" products are accused of infringing the '403 Patent Compl. ¶202

U.S. Patent No. 7,398,723 - "Trigger Forward Displacement System and Method"

• Issued: July 15, 2008 '723 Patent, front page

Technology Synopsis

The patent discloses a system where a pivoting cam, actuated by the firearm's reciprocating loading mechanism, pushes the trigger forward into a "ready to fire position" '723 Patent, abstract This method is intended to increase the cyclic rate of a semi-automatic firearm '723 Patent, col. 1:7-12

• Asserted Claims: The complaint asserts one or more claims including independent claim 1 Compl. ¶99
• Accused Features: The "Super Safety" product is accused of infringing the '723 Patent Compl. ¶97

III. The Accused Instrumentality

Product Identification

Defendants are accused of infringing with their "Super Safety (3 Position)," "ARC-Fire," "Super Selector," and "Partisan Disruptor FRT" trigger mechanisms (collectively, the "Infringing Devices") Compl. ¶¶37 Compl. ¶46 Compl. ¶50 Compl. ¶52 The complaint also identifies various related kits and components, such as precut triggers, cam levers, "DB9 Titanium Trip Bar," and "Centering Blocks," which are allegedly specially designed for use with the primary accused devices Compl. ¶¶39-42

Functionality and Market Context

The accused products are aftermarket trigger systems for firearms, including AR-15 pattern rifles Compl. ¶¶27 Compl. ¶45 The complaint alleges these devices embody the patented "forced reset" technology, which uses the firearm's cycling action to mechanically reset the trigger, and can be switched by the user between a standard semi-automatic mode and the forced reset mode (Compl. ¶¶45; Compl. ¶49; Compl. ¶51; Compl. ¶55). The complaint includes a photograph of the "Super Safety" product components, showing a cam lever and other parts Compl. ¶55, p. 55 Defendants are alleged to sell these products through the "Deez Nutz Tactical" website and various Facebook groups Compl. ¶38

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:	The accused "Super Safety," "ARC-Fire," and "Super Selector" are alleged to be firearm trigger mechanisms that function as a cam to reset and lock the trigger Compl. ¶67	¶67; ¶68; ¶69	col. 2:24-26
a hammer having a sear catch and a hook for engaging a disconnector...	The accused products are installed with a hammer that has a sear catch and a hook for engaging a disconnector Compl. ¶67 A plaintiff-generated rendering depicts this hammer Compl. ¶67, p. 23	¶67	col. 4:24-27
a trigger member having a sear and adapted to be mounted...to pivot...	The accused products are installed with a trigger member that has a sear and pivots on a transverse axis Compl. ¶67	¶67	col. 3:51-64
a disconnector having a hook for engaging said hammer...	The accused products are installed with a disconnector that has a hook for engaging the hammer Compl. ¶67	¶67	col. 4:27-34
a cam having a cam lobe and adapted to be movably mounted...	The accused products allegedly have a cam with a cam lobe that is movably mounted in the fire control pocket Compl. ¶67	¶67	col. 4:55-67
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 accused cam is alleged to be movable between two positions, where in the second ("forced reset") position, the cam lobe mechanically moves the trigger member toward its set position Compl. ¶67	¶67	col. 5:22-29
whereupon in a standard semi-automatic mode, said cam is in said first position, rearward movement of the bolt carrier causes...disconnector hook [to] catc[h] said hammer hook...at which time a user must manually release said trigger member...	In the standard mode, the accused products allegedly operate such that the disconnector catches the hammer, requiring the user to manually release the trigger to fire again Compl. ¶67	¶67	col. 5:30-47
whereupon in a forced reset semi-automatic mode, said cam is in said second position...said disconnector hook is prevented from catching said hammer hook...at which time the user can pull said trigger member to fire the firearm.	In the "forced reset" mode, the accused products allegedly operate such that the disconnector is prevented from catching the hammer, allowing the user to fire again without manually releasing the trigger Compl. ¶67	¶67	col. 5:48-64

'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:	The accused "Super Safety," "ARC-Fire," and "Super Selector" are alleged to be or be part of a trigger mechanism that functions as an extended trigger member locking device Compl. ¶83	¶83; ¶84; ¶85	col. 1:5-8
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 accused devices allegedly operate as a locking member movable between a first locked position and a second unlocked position Compl. ¶83	¶83	col. 2:14-19
the locking member configured to be movably supported by a frame and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier,	The accused devices allegedly have an upward extending portion (lever arm) that is movably supported by the firearm's frame (lower receiver) and is configured to make actuating contact with the bolt carrier Compl. ¶83	¶83	col. 2:20-25
such actuating contact causing the locking member to move from the first position to the second position,	The alleged contact between the bolt carrier and the upward extending portion causes the locking member to move from the locked to the unlocked position Compl. ¶83	¶83	col. 2:26-28
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 accused devices are alleged to have a body portion and an upwardly extending deflectable portion (lever arm), with the complaint asserting that the connection between them is designed to allow separate movement of the lever arm relative to the body portion Compl. ¶84	¶84	col. 2:29-35

Identified Points of Contention

• Scope Questions: A central dispute may arise over the term "forces" in claim 15 of the '247 Patent. The court will need to determine whether the accused mechanism's interaction with the trigger meets the claimed requirement of actively forcing it to the set position. For the '784 Patent, a key scope question will be whether the term "separately movable," as applied to the "deflectable portion" relative to the "body portion," requires a multi-piece, hinged construction or if it can read on a single, flexible component.
• Technical Questions: The infringement allegations rely heavily on plaintiff-generated renderings of the accused products' internal operations Compl. ¶67, p. 23 Compl. ¶83, p. 58 A technical question for the court will be whether these renderings accurately depict the function of the accused products. The defense may argue that the actual operation of their devices differs from these diagrams in a way that avoids infringement of one or more claim limitations.

V. Key Claim Terms for Construction

For U.S. Patent No. 12,038,247

• The Term: "forces said trigger member towards said set position" (from claim 15).
• Context and Importance: This term is the functional core of the "forced reset" concept. Its construction will be critical to determining infringement. Practitioners may focus on this term because the nature and directness of the "forcing" action will be a central point of contention.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's summary describes the invention as one that "causes the trigger to be forcibly reset" without specifying a particular mechanism, which may support a broader functional definition '247 Patent, col. 2:48-49
  • Evidence for a Narrower Interpretation: The detailed description and figures show a specific embodiment where a cam lobe makes direct physical contact with the trigger member to push it into the reset position, which may support a narrower construction requiring direct mechanical displacement '247 Patent, Fig. 9D

For U.S. Patent No. 12,031,784

• The Term: "separately movable relative to the body portion" (from claim 1).
• Context and Importance: This term defines the key structural innovation claimed to overcome prior art limitations. The infringement analysis for this patent will likely hinge on whether the accused device's lever arm is "separately movable" from its main body.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the invention as allowing a locking member to "deflect or fold separately," which could be interpreted to encompass a wide range of relative movements, including flexing '784 Patent, col. 2:9-11
  • Evidence for a Narrower Interpretation: The figures for one embodiment explicitly show the "deflectable portion" (22) and the "body portion" (26) as distinct components connected by a "transverse pivot pin" (24), suggesting "separately movable" may require a multi-piece, hinged assembly '784 Patent, Figs. 2-4

VI. Other Allegations

Indirect Infringement

Plaintiffs allege both induced and contributory infringement for all asserted patents. Inducement allegations are based on Defendants' advertising, promotional materials, and instructions on how to install and use the infringing devices Compl. ¶¶70 Compl. ¶86 Contributory infringement is alleged based on the sale of components, such as the "DB9 Titanium Trip Bar" and "Centering Blocks," that are claimed to be specially designed for use in an infringing manner and not suitable for substantial non-infringing use Compl. ¶¶72 Compl. ¶88

Willful Infringement

Plaintiffs allege that Defendants' infringement is willful. The allegations are based on knowledge of the patents, at least as of the service of a prior amended complaint Compl. ¶¶73 Compl. ¶89 For the '247 Patent specifically, pre-suit knowledge is alleged based on a cease and desist letter sent on March 31, 2025 Compl. ¶73

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

• A core issue will be one of definitional scope: For the '247 patent family, can the accused products' operation be mapped to the specific functional steps of the claims, particularly whether the trigger is "forced" to its set position in the manner claimed? For the '784 patent, the dispute will likely center on whether the accused device's lever mechanism meets the "separately movable" limitation, or if it represents a different, non-infringing design.
• A key evidentiary question will be one of technical accuracy: The complaint's infringement theories are supported by plaintiff-generated diagrams. A central question for the court will be whether these diagrams are accurate representations of the accused products' structure and operation, or if there is a fundamental mismatch that negates infringement.
• The case also raises a significant question of willfulness and damages: Given that this is a multi-district litigation involving a Sixth Amended Complaint and allegations of a pre-suit notice letter, the proceedings will likely focus heavily on when Defendants gained knowledge of each patent and whether their continued conduct was objectively reckless, which would have substantial implications for potential damages.