DCT

4:26-cv-01001

ABC IP LLC v. Stryke Gunworks LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-2358, D.S.C., 06/17/2026
  • Venue Allegations: Venue is alleged to be proper in the District of South Carolina because the Defendant resides in the district and has a regular and established place of business there.
  • Core Dispute: Plaintiffs allege that Defendant's Kabuto forced reset trigger mechanism infringes four patents related to selectable, forced reset firearm trigger mechanisms.
  • Technical Context: The technology relates to trigger mechanisms for semi-automatic firearms, specifically "forced reset" triggers that use the firearm's cycling action to reset the trigger, potentially allowing for a faster rate of fire than standard mechanisms.
  • Key Procedural History: Plaintiff ABC IP, LLC is the owner by assignment of the Asserted Patents, and Plaintiff Rare Breed Triggers, Inc. is the exclusive licensee. The complaint does not mention any other prior litigation, licensing history, or post-grant proceedings.

Case Timeline

Date Event
2021-11-05 U.S. Patent No. 12,031,784 Priority Date
2022-01-10 U.S. Patent No. 12,636,403 Priority Date
2022-09-08 U.S. Patent No. 12,038,247 Priority Date
2022-09-08 U.S. Patent No. 12,578,159 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
2026-03-17 U.S. Patent No. 12,578,159 Issue Date
2026-05-26 U.S. Patent No. 12,636,403 Issue Date
2026-06-17 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 (the "'247 Patent") Compl. ¶9

The Invention Explained

  • Problem Addressed: The patent's background section notes that in a standard semi-automatic firearm, the disconnector holds the hammer after firing until the user manually releases and resets the trigger, which limits the potential rate of fire Compl. Ex. A, '247 Patent, col. 1:28-40 While users have employed techniques like "bump firing" to increase the rate of fire, the patent seeks a more integrated mechanical solution Compl. Ex. A, '247 Patent, col. 1:41-54
  • The Patented Solution: The patent describes a trigger mechanism, intended as a "drop-in" module, that provides selectable modes of operation: safe, standard semi-automatic, and forced reset semi-automatic Compl. Ex. A, '247 Patent, abstract Compl. Ex. A, '247 Patent, col. 2:22-27 In the forced reset mode, a pivoting cam, actuated by the rearward movement of the firearm's bolt carrier, mechanically forces the trigger member back to its "set" position Compl. Ex. A, '247 Patent, col. 2:56-61 A key aspect is the interaction with a three-position safety selector, which, when in the forced reset position, "disables" the disconnector, preventing it from catching the hammer and thereby allowing for immediate subsequent firing once the trigger is reset by the cam Compl. Ex. A, '247 Patent, col. 8:55-65
  • Technical Importance: The invention aims to provide a modular trigger assembly that allows a user to select a "forced reset" mode to increase the potential rate of semi-automatic fire, without requiring modification to other standard components like the bolt carrier Compl. Ex. A, '247 Patent, col. 2:20-27

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶28
  • The essential elements of independent claim 15 include:
    • A firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a cam.
    • The cam is movable between a first position (for standard mode) and a second position where its lobe forces the trigger member toward its set position.
    • In a "standard semi-automatic mode," the cam is in the first position, the disconnector hook catches the hammer hook, and the user must manually release the trigger to fire again.
    • In a "forced reset semi-automatic mode," the cam is in the second position, the disconnector hook is "prevented from catching said hammer hook," and the user can pull the trigger again to fire once the action has cycled.
  • The complaint reserves the right to assert other claims of the '247 Patent Compl. ¶28

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

  • Issued: July 9, 2024 (the "'784 Patent") Compl. ¶10

The Invention Explained

  • Problem Addressed: The patent background explains that a forced reset trigger designed for one firearm platform (e.g., an AR-15) may be inoperable in a related but dimensionally different platform (e.g., an AR-10) Compl. Ex. B, '784 Patent, col. 1:21-32 This is because the locking member that interacts with the bolt carrier may be too short to be actuated, or if lengthened, it may interfere with the bolt carrier's rearward cycling movement Compl. Ex. B, '784 Patent, col. 1:37-44
  • The Patented Solution: The invention is an extended trigger member locking device featuring a "deflectable" or "folding" upward extension Compl. Ex. B, '784 Patent, abstract This extension piece is designed to be long enough to be actuated by the bolt carrier as it returns to its forward, in-battery position, but it is also able to pivot or fold out of the way to allow a different portion of the bolt carrier to pass without interference as it cycles to the rear Compl. Ex. B, '784 Patent, col. 2:45-52 The specification shows embodiments where this is achieved with a hinge and spring mechanism Compl. Ex. B, '784 Patent, Figs. 2-4
  • Technical Importance: This design allows a single forced reset trigger mechanism to be compatible with multiple firearm platforms that have different bolt carrier dimensions and profiles, enhancing its modularity and application range Compl. Ex. B, '784 Patent, col. 1:21-44

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶42
  • The essential elements of independent claim 1 include:
    • An extended trigger member locking device for a forced reset trigger mechanism.
    • A locking member movable between a first (locking) and second (non-restricting) position, actuated by contact with a bolt carrier.
    • The locking member comprises a "body portion" that is movably supported.
    • The locking member also comprises 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 of the '784 Patent Compl. ¶42

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

  • Issued: March 17, 2026 (the "'159 Patent") Compl. ¶11
  • Technology Synopsis: The '159 Patent discloses a firearm trigger mechanism operable in a standard semi-automatic mode and a forced reset semi-automatic mode Compl. Ex. C, '159 Patent, abstract Like the '247 Patent, it addresses the problem of increasing the rate of semi-automatic fire Compl. Ex. C, '159 Patent, col. 1:19-25 The solution involves a cam that interacts with the bolt means to force the trigger toward its set position, with a distinction in operation between the two modes based on whether the disconnector is permitted to hold the hammer Compl. Ex. C, '159 Patent, claim 1
  • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶56
  • Accused Features: The complaint alleges that the Kabuto product, when installed, functions as a forced reset trigger mechanism with selectable standard and forced reset modes, infringing the claims of the '159 Patent Compl. ¶¶58-59

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

  • Issued: May 26, 2026 (the "'403 Patent") Compl. ¶12
  • Technology Synopsis: The '403 Patent describes a trigger mechanism with a three-position safety selector for safe, standard semi-automatic, and forced reset semi-automatic modes Compl. Ex. D, '403 Patent, abstract It addresses the desire for a "drop-in" trigger module that can increase the rate of fire Compl. Ex. D, '403 Patent, col. 1:19-27 The solution centers on the interaction between a hammer, disconnector, trigger member, and a separate locking member, all governed by the safety selector to achieve the different operational modes Compl. Ex. D, '403 Patent, abstract
  • Asserted Claims: The complaint asserts independent claims 38 and 54 Compl. ¶70
  • Accused Features: The complaint alleges the Kabuto embodies the claimed invention by comprising a hammer, disconnector, trigger member, and a safety selector that enables both standard and forced reset operational modes Compl. ¶¶72-73

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the "Kabuto" product, which is sold as at least a partial kit Compl. ¶23 Compl. ¶24

Functionality and Market Context

  • The complaint alleges the Kabuto is a forced reset trigger mechanism designed for installation in firearms such as those of the AR-15 pattern Compl. ¶17 Compl. ¶24 It is sold via the Defendant's website Compl. ¶24 The complaint includes a product photograph from this website for a kit labeled "Metal Mini T.U.R.D. 'Plops' ART" Compl. ¶25, p. 6
  • The Kabuto is described as being operable in a "disconnector mode," similar to a standard semi-automatic trigger, and a "forced reset semiautomatic with cam" mode Compl. ¶26
  • A user allegedly switches between these modes by moving the safety selector Compl. ¶26
  • The complaint alleges that the Kabuto kit includes, at a minimum, "the cam and cam lever components" which, when installed with other standard firearm parts, create the allegedly infringing mechanism Compl. ¶24

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 Kabuto, when installed, is alleged to be part of a forced reset trigger mechanism. ¶30 col. 2:17-27
a hammer having a sear catch and a hook for engaging a disconnector... The Kabuto is installed with a hammer (Red) that allegedly has a sear catch and a hook for engaging a disconnector. ¶30 col. 7:45-48
a trigger member having a sear... The Kabuto is installed with a trigger member (Brown) that allegedly has a sear. ¶30 col. 7:50-54
wherein said sear and sear catch are in engagement in said set positions of said hammer and trigger member The sear of the trigger member and sear catch of the hammer are alleged to be in engagement in their set positions. ¶30 col. 7:55-58
said disconnector having a hook for engaging said hammer... The system includes a disconnector (Orange) with a hook for engaging the hammer. ¶30 col. 7:63-66
and a cam having a cam lobe and adapted to be movably mounted... 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 Kabuto allegedly has a cam (Green) with a cam lobe and lever (Blue) that forces the trigger member toward the set position when in the forced reset mode. ¶30 col. 8:1-13
whereupon in a standard semi-automatic mode... said disconnector hook catches said hammer hook... at which time a user must manually release said trigger member... In standard mode, the disconnector (Orange) allegedly catches the hammer (Red), requiring the user to manually release the trigger member (Brown) to reset and fire again. ¶30 col. 9:1-25
whereupon in a forced reset semi-automatic mode... 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 cam (Green) allegedly forces the trigger to reset, and the disconnector (Orange) is prevented from catching the hammer, allowing the user to fire again without a manual release. ¶30 col. 9:26-57

'784 Patent 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: The Kabuto is alleged to function as an extended trigger member locking device. ¶44 col. 2:53-59
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 Kabuto (yellow, blue, and purple components) allegedly operates as a locking member movable between a locked first position and an unlocked second position. ¶44 col. 2:53-59
...including a generally upward extension portion configured to make actuating contact with a surface of the bolt carrier, The Kabuto allegedly has an upward extending "lever arm" (yellow) that makes actuating contact with the bolt carrier. ¶44 col. 2:59-62
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 Kabuto is alleged to have a body portion (blue) and an upwardly extending deflectable portion (lever arm, yellow) that is separately movable. The complaint includes plaintiff-generated diagrams intended to illustrate this separate movement Compl. ¶44, p. 24 ¶44 col. 2:60-64

Identified Points of Contention

  • Scope Questions: For the '784 Patent, a central issue may be the construction of "separately movable relative to the body portion." The patent illustrates this with a distinct hinge pin connecting two components '784 Patent, Fig. 2 The infringement analysis will likely focus on whether the accused Kabuto's "lever arm" and "body" are constructed in a way that meets this "separately movable" limitation, or if they are of a unitary or different multi-piece construction that falls outside the claim's scope.
  • Technical Questions: For the '247 Patent, a key technical question will be how the accused Kabuto achieves the "forced reset" mode. The complaint's infringement theory, supported by a plaintiff-generated diagram, maps the Kabuto's components to the claim elements Compl. ¶30, p. 8 A point of contention may be whether the Kabuto, when installed, performs the specific function where the safety selector's position "prevent[s] said disconnector hook from catching said hammer hook" in the exact manner claimed.

V. Key Claim Terms for Construction

Term ('247 Patent, claim 15): "preventing said disconnector hook from catching said hammer hook"

  • Context and Importance: This phrase defines the critical distinction in the claimed invention between the standard and forced reset modes. Infringement depends on whether the accused device achieves this "prevention" function. Practitioners may focus on this term because the method of disabling the disconnector is the core of the forced reset mode's operation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional and does not specify a particular structure for achieving the prevention. An argument could be made that any mechanism that disables the disconnector's ability to catch the hammer would satisfy this limitation.
    • Evidence for a Narrower Interpretation: The specification describes a specific structural implementation where a "narrow semi-circular portion (116)" of the safety selector "prevents the disconnector (60) from pivoting with the trigger member (38) thus preventing the disconnector hook (64) from catching the hammer hook" Compl. Ex. A, '247 Patent, col. 8:55-63 A party may argue that this detailed description limits the claim's scope to this specific mechanical interaction.

Term ('784 Patent, claim 1): "upwardly extending deflectable portion that is separately movable relative to the body portion"

  • Context and Importance: This term describes the central novel feature of the '784 Patent, intended to solve the problem of trigger compatibility between different firearm platforms. The dispute may hinge on whether the accused device's construction meets this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "separately movable." The specification also mentions that the extension portion "could be made from a resilient material configured to deflectably bend" Compl. Ex. B, '784 Patent, col. 3:55-59, which might support a construction that includes flexing of a single piece, not just pivoting of multiple pieces.
    • Evidence for a Narrower Interpretation: The patent's illustrated embodiments exclusively show a multi-piece construction where the "deflectable portion" (22, 50) pivots relative to the "body portion" (26, 52) on a distinct hinge pin (24, 54) Compl. Ex. B, '784 Patent, Figs. 2-4 Compl. Ex. B, '784 Patent, Figs. 8-10 This may support an argument that "separately movable" requires a physically separate, hinged component.

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 Kabuto to infringe Compl. ¶31 Compl. ¶45 Compl. ¶59 Compl. ¶74 Contributory infringement is based on the allegation that the components of the Kabuto "are not suitable for substantial noninfringing use as they are specially designed and adapted to be used in a fire control unit to forcibly reset a trigger mechanism" Compl. ¶33 Compl. ¶47 Compl. ¶61 Compl. ¶76

Willful Infringement

  • Willfulness is alleged for all asserted patents. The complaint claims Defendant engaged in "egregious infringement behavior with knowledge of the" patents and "has known or should have known" that its actions constituted infringement, at least from the service of the complaint Compl. ¶34 Compl. ¶48 Compl. ¶62 Compl. ¶77

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

  • A core issue will be one of claim construction and scope: For the '784 patent, can the term "separately movable deflectable portion," which is illustrated in the patent as a distinct, hinged component, be construed to read on the specific design of the accused Kabuto's lever arm? The resolution of this question may determine infringement of that patent.
  • A key evidentiary question will be one of functional operation: For the '247, '159, and '403 patents, which claim selectable-mode triggers, does the accused Kabuto, when installed, create a mechanism where the safety selector and disconnector interact to functionally "prevent" the disconnector from catching the hammer in the forced-reset mode, as required by the claims, or is there a material difference in the mechanical means by which the modes operate?
  • A significant factual question will be one of indirect infringement: As the accused product is alleged to be sold as a kit, the case may heavily rely on whether the components have any "substantial noninfringing use." Proving the absence of such a use will be critical to Plaintiffs' theory of contributory infringement.