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: ABC IP, LLC, et al. v. Jacob Rusty Burse D/B/A Shackleford's FRT, 1:26-cv-1118, 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 in the Western District of Tennessee.
• Core Dispute: Plaintiffs allege that Defendant's "Super Safety" firearm trigger kits and related products infringe five U.S. patents concerning "forced reset" trigger mechanisms.
• Technical Context: The technology involves trigger mechanisms for semi-automatic firearms, such as AR-pattern rifles, designed to use the force of the firearm's cycling action to reset the trigger, thereby enabling a faster potential rate of fire than standard mechanisms.
• Key Procedural History: The complaint notes that Plaintiff Rare Breed Triggers has used the "FRT" trademark since at least 2020 to identify its own trigger systems and possesses several federal trademark registrations and applications for marks including the "FRT" formative.

Case Timeline

Date	Event
2020-01-01	Approximate date Plaintiffs began using "FRT" trademark (earliest date)
2021-11-05	Priority Date for '784 Patent
2022-01-10	Priority Date for '403 Patent
2022-09-08	Priority Date for '247 Patent
2022-09-08	Priority Date for '159 Patent
2023-12-04	Priority Date for '538 Patent
2024-07-09	U.S. Patent No. 12,031,784 Issues
2024-07-16	U.S. Patent No. 12,038,247 Issues
2026-01-20	U.S. Patent No. 12,529,538 Issues
2026-03-17	U.S. Patent No. 12,578,159 Issues
2026-05-26	U.S. Patent No. 12,636,403 Issues
2026-05-29	Complaint Filed

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.

The Invention Explained

• Problem Addressed: The patent's background section describes the operational limits of a standard semi-automatic trigger, which includes a disconnector to ensure only one shot is fired per pull of the trigger Compl. ¶21 '247 Patent, col. 1:21-47 The patent notes a desire among some shooters to increase the rate of semi-automatic fire, and the limitations of prior art methods like "bump firing" Compl. ¶21 '247 Patent, col. 1:48-54
• The Patented Solution: The invention is a trigger mechanism, adaptable as a "drop-in" module, with a three-position safety selector: safe, standard semi-automatic, and forced reset semi-automatic Compl. ¶23 '247 Patent, abstract In the "forced reset" mode, the rearward movement of the firearm's bolt carrier causes a cam to pivot, which in turn forces the trigger member back to its set position Compl. ¶22 '247 Patent, col. 2:57-3:10 This mechanical reset allows a user to fire again without first needing to manually release the trigger, enabling a higher rate of fire.
• Technical Importance: The technology provides a self-contained, selectable system to significantly increase the cyclic rate of a standard semi-automatic firearm, such as an AR-pattern rifle, by automating the trigger reset function through the firearm's own action Compl. ¶23 '247 Patent, abstract

Key Claims at a Glance

• The complaint asserts independent claim 15 Compl. ¶40
• Essential elements of claim 15 include:
  • A firearm trigger mechanism with a hammer, trigger member, disconnector, and a movable cam with a cam lobe.
  • The mechanism operates in both a "standard semi-automatic mode" and a "forced reset semi-automatic mode."
  • In standard mode, after firing, the disconnector hook catches the hammer hook, and the user must manually release the trigger to reset the mechanism.
  • In forced reset mode, the cam lobe forces the trigger member toward its set position, and the disconnector hook is prevented from catching the hammer hook, allowing the user to fire again once the bolt carrier returns to battery.
• The complaint reserves the right to assert other claims Compl. ¶40

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.

The Invention Explained

• Problem Addressed: The patent explains that a forced reset trigger designed for one firearm platform (e.g., an AR-15) may not be operable in another (e.g., an AR-10) due to different bolt carrier geometry Compl. ¶24 '784 Patent, col. 1:20-44 Specifically, extending a locking member to be actuated by the differently-positioned AR-10 bolt carrier would cause it to interfere with another part of the bolt carrier as it cycles rearward, rendering the device inoperable '784 Patent, col. 1:37-44
• The Patented Solution: The invention is an extended trigger member locking device featuring a "deflectable" or "one-way" hinged upward extension '784 Patent, abstract '784 Patent, col. 2:5-10 This extension is long enough to be actuated by the bolt carrier upon its return to battery but is designed to fold or deflect out of the way when contacted by a different part of the bolt carrier during its rearward travel, thus avoiding interference '784 Patent, abstract '784 Patent, col. 4:25-36
• Technical Importance: The design allows a forced reset trigger mechanism to be adapted for use across multiple firearm platforms with varying dimensions and geometries, which was a limitation of prior designs Compl. ¶24 '784 Patent, col. 1:20-44

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶54
• 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 (locked) and second (unlocked) position.
  • The locking member has a body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion."
  • This deflectable portion is configured to make "actuating contact" with the bolt carrier, causing the locking member to move from the first to the second position.
• The complaint reserves the right to assert other claims Compl. ¶54

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

• Patent Identification: U.S. Patent No. 12,529,538, "Safety Mechanism for Firearm," issued January 20, 2026.
• Technology Synopsis: The patent describes a safety mechanism comprising a cam selector, a lever, and a trigger Compl. ¶25 '538 Patent, abstract The cam selector features multiple recesses on its bottom side that interact with a tail portion of the trigger to enable three distinct modes of operation: a standard semi-automatic mode, an "active reset" mode, and a safe mode that prevents the trigger from being pulled Compl. ¶25 '538 Patent, abstract
• Asserted Claims: The complaint asserts independent claim 1 Compl. ¶68
• Accused Features: The "Super Safety" product is alleged to embody this technology through its use of a multi-mode cam selector that interacts with the trigger to provide selectable firing modes (Compl. ¶¶29; Compl. ¶70).

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

• Patent Identification: U.S. Patent No. 12,578,159, "Firearm Trigger Mechanism," issued March 17, 2026.
• Technology Synopsis: The patent discloses a trigger mechanism operable in two modes: a standard semi-automatic mode and a forced reset semi-automatic mode Compl. ¶23 '159 Patent, abstract The mechanism uses a cam, rotated by the cycling of the firearm's bolt, to force the trigger member to its reset position in the forced reset mode, thereby accelerating the potential firing sequence Compl. ¶23 '159 Patent, col. 14:48-65
• Asserted Claims: The complaint asserts independent claim 1 Compl. ¶82
• Accused Features: The "Super Safety" is accused of infringing by allegedly incorporating a selectable dual-mode (standard and forced reset) trigger system operated by a cam (Compl. ¶¶29; Compl. ¶84).

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

• Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism," issued May 26, 2026.
• Technology Synopsis: This patent describes a trigger mechanism with a safety selector movable between a standard semi-automatic position and a forced reset semi-automatic position Compl. ¶26 '403 Patent, abstract A key feature is that in the standard mode, the user must reduce pressure on the trigger to permit reset, whereas in the forced reset mode, the cycling action forces the trigger to reset, allowing the user to fire again without releasing pressure '403 Patent, col. 11:34-51
• Asserted Claims: The complaint asserts independent claim 38 Compl. ¶96
• Accused Features: The "Super Safety" product is alleged to infringe by including a safety selector that enables switching between a standard semi-automatic mode and a forced reset mode with the described operational characteristics (Compl. ¶¶29; Compl. ¶98).

III. The Accused Instrumentality

Product Identification

The accused products are identified as the "(3-Position) 'Super Safety'" and its variants (collectively, the "Infringing Devices") Compl. ¶29

Functionality and Market Context

• The "Super Safety" is a trigger mechanism for AR-pattern firearms that allegedly embodies the technology of the Asserted Patents Compl. ¶29 It is offered for sale as a "partial kit," a "complete kit," or preinstalled in a firearm receiver Compl. ¶30.a-c The complaint provides a photo of a "Polished Super Safety W/ Precut Rounded Trig" kit offered for sale Compl. ¶31, p. 9
• Functionally, the installed product is alleged to provide a "forced reset trigger" mechanism Compl. ¶22 The user can allegedly switch between a "disconnector mode" and a "forced reset semiautomatic with cam" mode by moving the safety selector Compl. ¶32
• The complaint alleges that the Defendant markets its products using the term "FRT," which Plaintiffs claim as their trademark, and offers them for sale on a public website (Compl. ¶¶30; Compl. ¶35).

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 for engaging a disconnector...	The Super Safety is installed with a hammer that has a sear catch and a hook for engaging a disconnector.	¶42	col. 14:44-48
a trigger member having a sear...	The Super Safety is installed with a trigger member that has a sear.	¶42	col. 14:49-54
a disconnector having a hook for engaging said hammer...	The disconnector is adapted to be mounted and has a hook for engaging the hammer.	¶42	col. 14:62-66
a cam having a cam lobe and adapted to be movably mounted...	The Super Safety has a cam with a cam lobe and lever that is movably mounted in the fire control mechanism pocket.	¶42	col. 15:1-4
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 cam is movable, and in the second position, its lobe forces the trigger member toward the set position when in forced reset mode.	¶42	col. 15:5-9
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,	In standard mode, rearward bolt carrier movement causes the disconnector to catch the hammer hook, as depicted in a plaintiff-generated rendering.	¶42	col. 15:14-18
...at which time a user must manually release said trigger member to free said hammer from said disconnector to permit said hammer and trigger member to pivot to said set positions so that the user can pull said trigger member to fire the firearm, and	The user must manually release the trigger to free the hammer from the disconnector before firing again.	¶42	col. 15:22-29
whereupon in a forced reset semi-automatic mode, ... rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook,	In forced reset mode, rearward bolt carrier movement causes rearward pivoting of the hammer, and the disconnector hook is prevented from catching the hammer hook. This is shown in a rendering of the accused system Compl. ¶42, p. 23	¶42	col. 15:33-37
and thereafter the bolt carrier moves forward into battery, at which time the user can pull said trigger member to fire the firearm.	After the bolt carrier moves forward, the user can pull the trigger to fire the firearm without first releasing it.	¶42	col. 15:38-41

Identified Points of Contention

• Technical Question: The complaint's allegation that the disconnector hook is "prevented from catching said hammer hook" in the forced reset mode relies on plaintiff-generated renderings Compl. ¶42, p. 23 A central evidentiary question will be whether the physical "Super Safety" product actually functions in this manner, as this is a key distinction between the two claimed modes of operation.
• Scope Question: Claim 15 requires two distinct and complete modes of operation. The analysis will question whether the accused device's "disconnector mode" and "forced reset... mode" Compl. ¶32 correspond precisely to the specific functional sequences defined for the "standard semi-automatic mode" and "forced reset semi-automatic mode" in the claim language.

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 rest 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 of the trigger member,	The Super Safety is part of a forced reset trigger mechanism and functions as a locking device that is movable between a locked and unlocked position. A rendering shows the "Locked First Position" and "Unlocked Second Position" Compl. ¶56, p. 30	¶56	col. 5:12-19
the locking member configured to be movably supported by a frame	The Super Safety is movably supported by the firearm's lower receiver, which functions as the frame.	¶56	col. 5:19-20
and including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier,	The Super Safety is alleged to have an upward extending lever arm configured to make actuating contact with a surface of the bolt carrier.	¶56	col. 5:21-23
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 complaint alleges this patent overcomes geometric limitations by "allowing a locking member to deflect or fold separately from the body portion" Compl. ¶24 The infringement theory suggests the Super Safety's locking member has this deflectable structure.	¶56	col. 6:3-9

Identified Points of Contention

• Technical Question: The core of the infringement allegation rests on the accused "Super Safety" having a locking member with a "deflectable extension" that is "separately movable" from its body, as required by claim 1. A key factual question will be what the physical construction of the accused device is and whether it incorporates such a hinged, folding, or otherwise separately movable component.
• Scope Question: The term "separately movable" may become a point of contention. The patent specification illustrates both a multi-part, hinged embodiment '784 Patent, Figs. 2-4 and an embodiment where both portions pivot on a single axis '784 Patent, Figs. 8-10 The court may need to determine if the accused product's design, whatever it may be, falls within a reasonable construction of this term as supported by the intrinsic evidence.

V. Key Claim Terms for Construction

For the '247 Patent

• The Term: "forced reset semi-automatic mode" (from claim 15)
• Context and Importance: The definition of this term is fundamental, as it distinguishes the patented invention's primary functional advantage over the "standard semi-automatic mode." Infringement hinges on demonstrating that the accused device operates in a manner that satisfies all the functional limitations of this claimed mode.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent abstract and summary broadly describe the function as one where a cam "forces the trigger member to the set position" '247 Patent, abstract This general functional description could support a broader reading focused on the outcome of the trigger being reset by the action.
  • Evidence for a Narrower Interpretation: The specific language of claim 15 provides a detailed sequence of events for this mode, including that the "disconnector hook is prevented from catching said hammer hook" '247 Patent, col. 15:36-37 A party could argue this requires an active blocking or prevention mechanism, not merely a scenario where the hook happens not to catch, thereby narrowing the scope of the term to a specific mechanical implementation.

For the '784 Patent

• The Term: "upwardly extending deflectable portion that is separately movable relative to the body portion" (from claim 1)
• Context and Importance: This term describes the central inventive concept for adapting the trigger to different firearm geometries. Whether the accused device infringes will likely depend on whether its locking member has a component that meets this structural and functional definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification uses flexible language, stating the extension can "deflect or fold" and refers to a "one-way hinge feature" ('784 Patent, col. 2:7-9). An embodiment is also shown where the extension and body pivot on a single, coaxial axis '784 Patent, col. 4:40-44, which might support a construction where "separately movable" does not require distinct pivot points.
  • Evidence for a Narrower Interpretation: The primary embodiment illustrates the deflectable portion and the body as distinct parts joined by a separate pivot pin (24) and spring (28) '784 Patent, Figs. 2-4 '784 Patent, col. 3:41-52 This could be used to argue for a narrower construction requiring a multi-component, articulated assembly rather than a single, flexible piece.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that the Defendant encourages and instructs customers on how to install and use the "Super Safety" products Compl. ¶43 Compl. ¶57 Compl. ¶71 Compl. ¶85 Compl. ¶99 Contributory infringement is based on the sale of components, such as the "cam or cam lever arm," which are alleged to be specially designed for infringement and not suitable for substantial non-infringing use Compl. ¶45 Compl. ¶59 Compl. ¶73 Compl. ¶87 Compl. ¶101
• 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 "has known or should have known that its actions constituted... infringement" Compl. ¶46 Compl. ¶60 Compl. ¶74 Compl. ¶88 Compl. ¶102 These allegations suggest knowledge of the patents and a high likelihood of infringement.

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

• Evidentiary Question of Operation: A primary issue for the court will be one of technical function: does the accused "Super Safety" product, when physically tested, perform the precise, multi-step mechanical sequences recited in the asserted claims? The case may depend on expert testimony and evidence demonstrating whether, for example, the cam actively "prevents" the disconnector from engaging in one mode (per the '247 patent) or if the locking member is "separately movable" (per the '784 patent).
• Definitional Scope: The dispute will likely involve a significant claim construction battle over the meaning of key terms. A central question will be one of definitional scope: can terms like "separately movable" ('784 patent) and "prevented from catching" ('247 patent) be construed to cover the specific design and operation of the accused device, or is there a mismatch between the claim language and the accused product's structure?
• Contributory Infringement and Commercial Intent: A third key question relates to the viability of contributory infringement claims, which will turn on whether the components of the "Super Safety" kits have any "substantial non-infringing use." This analysis will be closely tied to the broader context of alleged willful infringement and the Defendant's alleged use of Plaintiffs' "FRT" trademark, which together form a narrative of intentional copying that may influence the court's view on intent and damages.