DCT

4:26-cv-00801

Rare Breed Triggers Inc v. Advanced Threat Assessment Training Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-14198, S.D. Fla., 06/05/2026
  • Venue Allegations: Venue is alleged to be proper as Defendant resides in the district and has a regular and established place of business there.
  • Core Dispute: Plaintiffs allege that Defendant's "Super Safety" and "Disruptor" aftermarket firearm components infringe nine U.S. patents related to forced reset trigger mechanisms.
  • Technical Context: The technology concerns trigger mechanisms for semi-automatic firearms, specifically those that use the cycling of the firearm's action to mechanically reset the trigger, enabling a faster rate of fire than is possible with standard designs.
  • Key Procedural History: The complaint notes that a cease and desist letter was delivered to the Defendant on March 25, 2025, providing notice of U.S. Patent No. 12,038,247 and accusing the "Super Safety" product of infringement.

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
2021-11-05 U.S. Patent No. 12,031,784 Priority Date
2022-01-10 U.S. Patent Nos. 11,724,003; 12,036,336; 12,274,807; 12,636,403 Priority Date
2022-09-08 U.S. Patent Nos. 12,038,247; 12,578,159 Priority Date
2023-08-15 U.S. Patent No. 11,724,003 Issue Date
2023-12-04 U.S. Patent No. 12,529,538 Priority Date
2024-07-09 U.S. Patent No. 12,031,784 Issue Date
2024-07-16 U.S. Patent No. 12,038,247 Issue Date
2024-07-16 U.S. Patent No. 12,036,336 Issue Date
2025-03-25 Cease and desist letter delivered to Defendant
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
2026-06-05 Complaint Filing Date

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

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

  • Patent Identification: U.S. Patent No. 12,038,247, "Firearm Trigger Mechanism", issued July 16, 2024 Compl. ¶9

The Invention Explained

  • Problem Addressed: The patent describes standard semi-automatic triggers as limiting the rate of fire because a user must manually release the trigger to allow the disconnector to reset the hammer, a process which is "not typically able to be done rapidly enough" to achieve a high cyclic rate '247 Patent, col. 1:30-35 Other methods for increasing fire rate, such as "bump firing," are noted as requiring practice to use reliably '247 Patent, col. 1:40-54
  • The Patented Solution: The invention is a trigger mechanism, often constructed as a "drop-in" module for AR-pattern firearms, that includes a cam. This cam is pivoted by the rearward motion of the firearm's bolt carrier during its cycle of operation. The cam's movement, in turn, forces the trigger member back to its set position. This "forced reset" allows a user to fire again as soon as the bolt carrier is back in battery, without needing to manually release the trigger. '247 Patent, abstract '247 Patent, col. 2:37-52 The mechanism is selectable, allowing operation in either this forced reset mode or a standard semi-automatic mode '247 Patent, abstract
  • Technical Importance: The technology provides a mechanical method to significantly increase the potential rate of fire for common semi-automatic firearms while being adaptable for construction as a "drop-in" replacement module that requires minimal modification to the host firearm '247 Patent, col. 2:37-41

Key Claims at a Glance

  • The complaint asserts independent claim 15 and reserves the right to assert additional claims '247 Patent, claim 15 Compl. ¶45
  • Essential elements of independent 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 (for standard semi-automatic mode) and a second position (for forced reset mode).
    • In standard mode, the rearward movement of the bolt carrier causes the disconnector hook to catch the hammer hook, requiring the user to manually release the trigger to reset the mechanism for the next shot.
    • In forced reset mode, the cam is in its second position, and the rearward movement of the bolt carrier causes the cam lobe to force the trigger member to its set position, while also preventing the disconnector from catching the hammer, allowing the user to fire again without manually releasing the trigger.

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

  • Patent Identification: U.S. Patent No. 12,031,784, "Adapted Forced Reset Trigger", issued July 9, 2024 Compl. ¶10

The Invention Explained

  • Problem Addressed: The patent explains that forced reset trigger mechanisms designed for one firearm platform (e.g., an AR-15) may not be compatible with others (e.g., an AR-10) due to differences in the geometry and positioning of the bolt carrier relative to the trigger components. A locking member tall enough for an AR-10 might interfere with the bolt carrier of an AR-15, while one designed for an AR-15 might be too short to be actuated in an AR-10. '784 Patent, col. 2:21-44
  • The Patented Solution: The patent discloses an extended trigger locking device featuring a "deflectable portion." This upward-extending portion is actuated by the forward movement of the bolt carrier to unlock the trigger. Crucially, this portion is designed to "deflect or fold" out of the way when contacted by a lower surface on the forward part of the bolt carrier as it cycles to the rear, thus avoiding interference. '784 Patent, abstract '784 Patent, col. 2:4-12 '784 Patent, Fig. 7 This allows the locking device to be long enough for platforms with greater spacing while still being compatible with those with tighter clearances.
  • Technical Importance: This design feature allows a single forced reset trigger mechanism to be compatible across various firearm platforms with different internal geometries, overcoming a key limitation of prior art designs '784 Patent, col. 2:4-12

Key Claims at a Glance

  • The complaint asserts independent claim 1 and reserves the right to assert additional claims '784 Patent, claim 1 Compl. ¶59
  • Essential elements of independent claim 1 include:
    • In a forced reset trigger mechanism, an extended trigger member locking device, comprising:
    • A locking member movable between a first (locked) position and a second (unlocked) position.
    • The locking member is movably supported by a frame.
    • The locking member includes a "generally upward extension portion" that makes "actuating contact with a surface of the bolt carrier."
    • This contact causes the locking member to move from the first to the second position.

Multi-Patent Capsules

  • U.S. Patent No. 12,529,538

    • Patent Identification: U.S. Patent No. 12,529,538, "Safety Mechanism for Firearm", issued January 20, 2026 Compl. ¶11
    • Technology Synopsis: The patent describes a safety mechanism that uses a rotatable "cam selector" with multiple recesses on its underside. The mechanism operates in three modes: a standard semi-automatic mode, an "active reset" mode where the cam forces the trigger to reset, and a safe mode that prevents the trigger from being pulled. '538 Patent, abstract Compl. ¶28
    • Asserted Claims: Claim 1 is asserted Compl. ¶73
    • Accused Features: The "Super Safety" product is alleged to infringe, specifically its multi-mode safety selector and cam components Compl. ¶33 Compl. ¶73

  • U.S. Patent No. 12,578,159

    • Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism", issued March 17, 2026 Compl. ¶12
    • Technology Synopsis: The technology is a firearm trigger mechanism that can be selected to operate in either a standard semi-automatic mode or a forced reset semi-automatic mode. In the forced reset mode, a cam, rotated by the cycling of the firearm's action, forces the trigger member to reset and prevents it from being pulled again until the action is in battery. Compl. ¶26 '159 Patent, abstract
    • Asserted Claims: Claim 1 is asserted Compl. ¶87
    • Accused Features: The "Super Safety" product is alleged to infringe, particularly its dual-mode functionality and cam-based reset system Compl. ¶33 Compl. ¶87

  • U.S. Patent No. 10,514,223

    • Patent Identification: U.S. Patent No. 10,514,223, "Firearm Trigger Mechanism", issued December 24, 2019 Compl. ¶13
    • Technology Synopsis: The patent describes a trigger mechanism where the cycling of the bolt carrier causes the hammer to make contact with the trigger member, forcefully resetting it. A separate locking bar prevents the user from pulling the trigger again until the bolt carrier has returned to its in-battery position. '223 Patent, abstract Compl. ¶29
    • Asserted Claims: Claim 4 is asserted Compl. ¶73
    • Accused Features: The "Disruptor" product is alleged to infringe, specifically through its use of hammer contact to reset the trigger and a locking bar to ensure safety Compl. ¶37 Compl. ¶41

  • U.S. Patent No. 11,724,003

    • Patent Identification: U.S. Patent No. 11,724,003, "Firearm Trigger Mechanism", issued August 15, 2023 Compl. ¶14
    • Technology Synopsis: The patent describes a trigger mechanism with selectable modes: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode. The invention includes a hammer, trigger, disconnector, and a locking member, all operating in concert with a safety selector to provide these distinct functions. '003 Patent, abstract Compl. ¶30
    • Asserted Claims: Claim 4 is asserted Compl. ¶87
    • Accused Features: The "Disruptor" product is alleged to infringe through its selectable standard and forced-reset modes of operation Compl. ¶37 Compl. ¶40 Compl. ¶87

  • U.S. Patent No. 12,036,336

    • Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism", issued July 16, 2024 Compl. ¶15
    • Technology Synopsis: The technology is a trigger mechanism offering selectable standard and forced reset semi-automatic modes. In the forced reset mode, the safety selector is configured to reposition the disconnector to prevent it from catching the hammer, allowing for immediate subsequent firing once the trigger is reset by the hammer's rearward pivot. '336 Patent, abstract Compl. ¶30
    • Asserted Claims: Claim 3 is asserted Compl. ¶101
    • Accused Features: The "Disruptor" product is alleged to infringe through its selectable modes and safety selector that controls the disconnector's function Compl. ¶37 Compl. ¶40 Compl. ¶101

  • U.S. Patent No. 12,274,807

    • Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism", issued April 15, 2025 Compl. ¶16
    • Technology Synopsis: This patent describes a trigger mechanism with selectable standard and forced reset modes, controlled by a three-position safety selector. The invention focuses on the interaction between the hammer, trigger, disconnector, and a locking member to achieve either a standard manual reset or a forced mechanical reset. '807 Patent, abstract Compl. ¶30
    • Asserted Claims: Claim 1 is asserted Compl. ¶114
    • Accused Features: The "Disruptor" product is alleged to infringe through its use of a three-position selector to switch between standard and forced reset functionality Compl. ¶37 Compl. ¶40 Compl. ¶114

  • U.S. Patent No. 12,636,403

    • Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism", issued May 26, 2026 Compl. ¶17
    • Technology Synopsis: The patent describes a forced reset trigger mechanism with a safety selector for switching between standard and forced reset modes. In the standard mode, rearward pressure on the trigger must be reduced to fire again, while in the forced reset mode it does not. '403 Patent, abstract Compl. ¶30
    • Asserted Claims: Claim 38 is asserted Compl. ¶128
    • Accused Features: Both the "Super Safety" and "Disruptor" products are alleged to infringe through their selectable-mode functionality Compl. ¶33 Compl. ¶37 Compl. ¶128

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Super Safety" and the "Disruptor" as the infringing devices Compl. ¶32

Functionality and Market Context

  • The accused devices are aftermarket components for AR-pattern firearms, sold via Defendant's website Compl. ¶¶34, 38
  • The Super Safety is a three-position selector assembly that allegedly provides "safe," "standard semiautomatic with disconnector," and "forced reset semiautomatic with cam modes" Compl. ¶36 It is sold as partial kits, complete kits, or preinstalled in a firearm receiver (Compl. ¶34). A Plaintiff-generated rendering in the complaint depicts the "Super Safety Cam with Lobe and Lever" as a key component Compl. p. 15
  • The Disruptor is also described as a trigger assembly that enables switching between "safe," "standard semiautomatic with disconnector," and "forced reset semiautomatic" modes Compl. ¶40 In its forced reset mode, the complaint alleges that the "cycling of the action causes hammer contact with the trigger member to forcefully reset the hammer and trigger member" Compl. ¶41 A photograph from Defendant's website shows the Disruptor as a multi-part trigger assembly Compl. p. 9

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,038,247 Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
A firearm trigger mechanism comprising: a hammer having a sear catch and a hook... a trigger member having a sear... a disconnector having a hook... The Super Safety is alleged to be a trigger mechanism installed in a fire control pocket with a hammer, trigger member, and disconnector. ¶47 (p. 11) col. 8:5-35
and a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket, The Super Safety allegedly includes a cam with a cam lobe and lever that is movably mounted in the fire control mechanism pocket. ¶47 (p. 14) col. 8:36-39
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 position (forced reset mode) the cam lobe forces the trigger member toward its set position. ¶47 (p. 15) col. 9:51-10:2
whereupon in a standard semi-automatic mode... 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 standard mode, the Super Safety allegedly operates such that the disconnector hook catches the hammer, requiring the user to manually release the trigger to reset the mechanism. ¶47 (p. 17) col. 9:10-50
and 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... at which time the user can pull said trigger member to fire the firearm. In forced reset mode, the Super Safety's cam is allegedly in its second position, forcing the trigger to reset while preventing the disconnector from catching the hammer, allowing the user to fire without manually releasing the trigger. ¶47 (p. 18) col. 9:51-10:2

Identified Points of Contention

  • Technical Question: A key factual question for the court will be whether the component identified as a "cam" in the accused Super Safety performs the dual functions required by claim 15. Specifically, the evidence will need to show that in one position it allows for standard disconnector function, while in a second position it both forces the trigger to reset and actively prevents the disconnector from catching the hammer.
  • Scope Question: The infringement analysis will likely depend on whether the term "cam" is construed broadly to cover any pivoting component that forces a reset, or more narrowly to the specific geometry and interactions described in the '247 patent's specification, such as the cam ("72") acting on a cam follower ("58") on the trigger member ("38") '247 Patent, col. 9:22-26

U.S. Patent No. 12,031,784 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 Super Safety is alleged to be part of a forced reset trigger mechanism and to operate as a locking member with locked and unlocked positions. ¶61 (pp. 24-25) col. 3:29-39
the locking member configured to be movably supported by a frame The accused Super Safety is alleged to be movably supported by the firearm's lower receiver, which functions as the frame. ¶61 (p. 25) col. 3:29-31
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, The Super Safety allegedly has an upward extending lever arm configured to make contact with the bolt carrier. ¶61 (p. 26) col. 3:41-45
such actuating contact causing the locking member to move from the first position to the second position, The complaint alleges that contact from the bolt carrier causes the accused locking member to move from its locked to its unlocked position. ¶61 (p. 26) col. 4:8-22

Identified Points of Contention

  • Technical Question: The '784 patent's key innovation is an upward extension that is "separately movable relative to the body portion" to allow it to "deflect or fold" when the bolt carrier cycles rearward '784 Patent, abstract '784 Patent, col. 4:26-34 The complaint's infringement allegations focus on the forward actuation of the locking member by the bolt carrier (Compl. p. 26). A central technical question will be what evidence shows that the accused Super Safety's locking member possesses this separate, rearward-deflecting capability.
  • Scope Question: The dispute may turn on the construction of "extended trigger member locking device." Defendant may argue that its "Super Safety" is simply a safety selector and not the specific "locking device" described, or that its upward-extending arm is not a "deflectable portion" within the meaning of the patent.

V. Key Claim Terms for Construction

'247 Patent

  • The Term: "cam"
  • Context and Importance: The identity and function of the "cam" are central to the forced reset operation described in claim 15. Whether the accused component in the Super Safety legally constitutes a "cam" as claimed will be critical to the infringement analysis.
  • Intrinsic Evidence for a Broader Interpretation: Claim 15 itself describes the "cam" functionally as a "movably mounted" part with a "cam lobe" that is "movable between a first position and a second position" and "forces said trigger member towards said set position" '247 Patent, claim 15
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the cam ("72") pivots on a pin and interacts with a "cam follower" ("58") on the trigger member '247 Patent, col. 9:22-26 A party could argue the term should be limited to a component that operates via this specific pivoting interaction.

'784 Patent

  • The Term: "deflectable portion"
  • Context and Importance: The patent's solution to the problem of cross-platform compatibility is the "deflectable portion" of the locking member's upward extension. The core of the infringement question for this patent will be whether the accused Super Safety has a component that meets this definition.
  • Intrinsic Evidence for a Broader Interpretation: The claim language itself does not use the word "deflectable," referring only to a "generally upward extension portion" '784 Patent, claim 1 An argument could be made that the claims do not require this feature.
  • Intrinsic Evidence for a Narrower Interpretation: The patent's abstract explicitly states the invention has "an upwardly extending deflectable portion that is separately movable relative to the body portion." The Summary of the Invention and detailed description repeatedly emphasize that this portion is designed to "deflect or fold" to avoid interference during the bolt carrier's rearward travel '784 Patent, abstract '784 Patent, col. 2:4-12 '784 Patent, col. 4:26-34 This suggests the "deflectable" nature is a defining characteristic of the invention, potentially limiting the scope of the claims.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement allegation is based on Defendant's promotional materials and website, which allegedly instruct customers on how to install and use the infringing devices in AR-15 firearms (Compl. ¶48; Compl. ¶62). The contributory infringement allegation states that the components of the Super Safety and Disruptor are not suitable for substantial noninfringing use and are specially designed to be used in a manner that infringes the patents (Compl. ¶50; Compl. ¶64; Compl. ¶78).
  • Willful Infringement: Plaintiffs allege willful infringement based on Defendant's alleged knowledge of the patents. This knowledge is alleged to have been established for at least the '247 patent via a cease-and-desist letter sent on March 25, 2025 (Compl. ¶22; Compl. ¶51). For the remaining patents, knowledge is alleged "at least through the service of this complaint" (Compl. ¶65; Compl. ¶79).

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

  • Patent Scope vs. Accused Operation: A central issue will be one of technical and definitional scope. Does the accused "Super Safety" locking member have the specific "deflectable portion" described as the core innovation of the '784 patent, or is it a unitary piece? Similarly, does the accused "cam" in the '247 patent analysis perform the precise dual-mode function of both forcing a reset and preventing disconnector engagement as claimed? The case will likely require a detailed, mode-by-mode comparison of the accused devices against the functions recited in the claims.

  • Patent Portfolio Overlap: Plaintiffs have asserted nine patents related to forced reset triggers, many of which appear to share significant conceptual DNA (e.g., selectable modes, cam-based resets, locking bars). A key strategic question will be one of patent differentiation. The court will likely need to untangle the distinct contributions of each patent to determine if the accused products infringe some but not all of the asserted claims, and whether this overlap creates invalidity issues under 35 U.S.C. §§ 102 or 103.

  • Willfulness and Pre-Suit Notice: The complaint's specific allegation of a pre-suit cease-and-desist letter for the '247 patent raises a significant question of willfulness. The court will examine whether this letter provided sufficient notice and whether Defendant's continued conduct after receiving it was objectively reckless, which could expose Defendant to enhanced damages under 35 U.S.C. § 284.