DCT

4:26-cv-01124

ABC IP LLC v. Eye Candy Custom Firearms LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-01124, M.D. Fla., 08/03/2026
  • Venue Allegations: Venue is alleged to be proper as Defendants reside in the district, have committed acts of infringement in the district, and maintain a regular and established place of business in the district.
  • Core Dispute: Plaintiffs allege that Defendants’ aftermarket firearm components, including the "Super Safety," "Atrius Selector," and "Kabuto," infringe five patents related to "forced reset" trigger mechanisms.
  • Technical Context: The technology concerns trigger mechanisms for semi-automatic firearms, specifically designs that use the cycling of the firearm’s action to mechanically reset the trigger, potentially enabling a faster rate of fire than standard designs.
  • Key Procedural History: The filing is a First Amended Complaint. Plaintiff Rare Breed is identified as the exclusive licensee of the Asserted Patents, which are owned by Plaintiff ABC IP.

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 and 12,578,159 Priority Date
2023-12-04 U.S. Patent No. 12,529,538 Priority Date
2024-07-09 U.S. Patent No. 12,031,784 Issued
2024-07-16 U.S. Patent No. 12,038,247 Issued
2026-01-20 U.S. Patent No. 12,529,538 Issued
2026-03-17 U.S. Patent No. 12,578,159 Issued
2026-05-26 U.S. Patent No. 12,636,403 Issued
2026-08-03 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. ¶10

The Invention Explained

  • Problem Addressed: The patent addresses the desire to increase the rate of fire in semi-automatic firearms beyond what is typically possible with a standard trigger mechanism, which requires a user to manually release the trigger to reset the firing mechanism between shots (Compl. ¶¶19-20; ’247 Patent, col. 1:29-56). Prior art methods to achieve this, such as "bump firing," are based on recoil management, while previous mechanical "forced reset" triggers required modified bolt carriers '247 Patent, col. 1:57-64
  • The Patented Solution: The patent describes a "drop-in" trigger module for AR-pattern firearms that provides a "three position" safety selector for safe, standard semi-automatic, and "forced reset" semi-automatic modes ’247 Patent, abstract In the forced reset mode, the rearward movement of the standard bolt carrier causes a cam to pivot, which in turn mechanically forces the trigger member back to its set position, allowing the user to fire again immediately without first manually releasing the trigger ’247 Patent, col. 2:65-col. 3:10
  • Technical Importance: The invention purports to enable a rapid, mechanically forced trigger reset that can be retrofitted into standard firearms without requiring modification to other major components like the bolt carrier assembly Compl. ¶22 ’247 Patent, col. 2:20-29

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶41
  • Essential elements of claim 15 include:
    • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam, all mounted to pivot.
    • The mechanism is operable in a "standard semi-automatic mode", where rearward bolt movement cocks the hammer, the disconnector hook catches the hammer hook, and the user must manually release the trigger to free the hammer from the disconnector to fire again.
    • The mechanism is also operable in a "forced reset semi-automatic mode", where rearward bolt movement causes the cam to pivot and force the trigger member to its set position, while the safety selector prevents the disconnector hook from catching the hammer hook, allowing the user to fire again without manually releasing the trigger.
  • The complaint reserves the right to assert other claims Compl. ¶41

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. ¶11

The Invention Explained

  • Problem Addressed: The patent identifies a geometric incompatibility issue when using a forced reset trigger designed for one firearm platform (e.g., an AR-15) in another with different dimensions (e.g., an AR-10). A component (locking member) tall enough to be actuated by the AR-10's bolt carrier would interfere with the bolt carrier's rearward cycling, rendering the device inoperable (’784 Patent, col. 1:21-44).
  • The Patented Solution: The invention is an extended trigger locking device featuring an "upwardly extending deflectable portion that is separately movable relative to the body portion" ’784 Patent, abstract ’784 Patent, claim 1 This deflectable part is long enough to be actuated by the bolt carrier as it moves forward into battery, but it pivots or folds out of the way during the bolt carrier's rearward travel, thus avoiding interference ’784 Patent, col. 4:23-37 ’784 Patent, Fig. 7
  • Technical Importance: This design allows a single forced reset trigger architecture to be adapted for use across multiple firearm platforms with different bolt carrier geometries, which was a limitation of prior designs ’784 Patent, col. 2:49-54

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶57
  • Essential elements of claim 1 include:
    • An extended trigger member locking device for a forced reset trigger mechanism.
    • The device comprises a "locking member" movable between a first (locking) and second (unlocked) position.
    • The locking member has an upward extension to make "actuating contact" with a bolt carrier.
    • Critically, the locking member has a movably supported "body portion" and an "upwardly extending deflectable portion that is separately movable" relative to the body, moving between an "extended position" and a "deflected position".
  • The complaint reserves the right to assert other claims Compl. ¶57

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 Compl. ¶12
  • Technology Synopsis: The patent describes a safety mechanism for a firearm employing a cam selector, a lever, and a trigger, configured to operate in three modes Compl. ¶24 In a first (standard) mode, a trigger tail is movable within a first recess; in a second (active reset) mode, the trigger tail engages a second recess and is forced down by a cam portion as the selector rotates; and in a third mode, the trigger is prevented from being pulled (’538 Patent, abstract).
  • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶73
  • Accused Features: The "Super Safety" product is alleged to embody the technology claimed in the ’538 Patent (Compl. ¶¶28-29; Compl. ¶73).

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 Compl. ¶13
  • Technology Synopsis: This patent details a trigger mechanism operable in a "standard semi-automatic mode" and a "forced reset semi-automatic mode" (’159 Patent, abstract). In the standard mode, the disconnector catches the hammer, requiring a manual trigger release to reset. In the forced reset mode, rearward movement of the bolt means causes a cam to mechanically move the trigger toward its reset position, while the disconnector hook is prevented from holding the hammer, allowing the user to fire again without a manual release ’159 Patent, claim 1
  • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶87
  • Accused Features: The "Super Safety," "Atrius," and "Kabuto" products are all alleged to infringe the ’159 Patent Compl. ¶87

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 Compl. ¶14
  • Technology Synopsis: The patent describes a forced reset trigger mechanism with a safety selector for switching between a standard semi-automatic mode and a forced reset semi-automatic mode (Compl. ¶25; ’403 Patent, abstract). In the forced reset mode, the action's cycling forces the trigger to return to a set position, enabling immediate re-firing ’403 Patent, claim 54 The claims detail the specific interactions between the hammer, disconnector, and selector in each mode ’403 Patent, claim 38
  • Asserted Claims: The complaint asserts independent claims 38 and 54 Compl. ¶103
  • Accused Features: The "Infringing Devices," which include the Super Safety, Atrius, and Kabuto, are alleged to infringe the ’403 Patent Compl. ¶103

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "(3-Position) Super Safety," the "(3-Position) Atrius Forced Reset Selector" (Atrius Selector), and the "Kabuto" device (collectively, "Infringing Devices") Compl. ¶¶27-39

Functionality and Market Context

  • The complaint alleges these are aftermarket trigger components or kits for AR-pattern firearms, sold either as standalone parts, in kits, or pre-installed in firearms Compl. ¶29 Compl. ¶33 Their alleged core function is to provide a selectable "forced reset" capability, which uses the cycling of the firearm's bolt carrier to mechanically reset the trigger Compl. ¶21 This functionality is alleged to allow a user to switch between a standard semi-automatic mode, which requires a manual trigger release between shots, and a "forced reset" mode that enables a higher rate of fire by eliminating the need for a manual release Compl. ¶31 Compl. ¶35 Compl. ¶39 An exemplary product photograph shows the "Super Safety" components, including a cam and a lever Compl. ¶30

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: When installed, the Super Safety, Atrius Selector, and Kabuto allegedly become part of a trigger mechanism that functions as a cam to cause trigger reset and lock the trigger. ¶43 col. 2:20-24
a hammer having a sear catch and a hook for engaging a disconnector... The accused products are allegedly installed with a hammer (red) that has a sear catch and a hook for engaging a disconnector (orange). A plaintiff-generated rendering depicts this combination. ¶43 col. 7:48-52
a trigger member having a sear... The accused products are allegedly installed with a trigger member (brown) that has a sear. ¶43 col. 7:53-56
and a cam having a cam lobe and adapted to be movably mounted... The accused products allegedly include a cam with a cam lobe and lever, shown in yellow in plaintiff-generated diagrams. ¶43 col. 8:1-4
whereupon in a standard semi-automatic mode... said disconnector hook catches said hammer hook,... a user must manually release said trigger member to free said hammer... In standard mode, rearward bolt movement allegedly causes the disconnector (orange) to catch the hammer (red), requiring a manual trigger release to fire again. ¶43 col. 8:50-64
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 is allegedly in a second position where it mechanically moves the trigger to the set position, and the disconnector hook is prevented from catching the hammer hook. ¶43 col. 9:30-48
  • Identified Points of Contention:
    • Technical Question: The complaint relies heavily on plaintiff-generated, color-coded renderings to illustrate infringement (Compl. ¶43). A central question for the court will be whether these diagrams accurately represent the structure and, more importantly, the precise mechanical operation of the accused Super Safety, Atrius, and Kabuto products.
    • Scope Question: Claim 15 recites a specific mechanism for the "forced reset" mode, wherein the "disconnector hook is prevented from catching said hammer hook." The infringement analysis will likely focus on whether the accused products achieve a forced reset through this exact method, or through a technically different means that may fall outside the literal scope of the claim.

'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 Super Safety is allegedly part of a forced reset trigger mechanism and functions as an extended trigger member locking device. ¶59 col. 5:11-13
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 Super Safety allegedly operates as a locking member, moving between a locked first position and an unlocked second position. ¶59 col. 3:13-22
the locking member having a body portion that is movably supported The Super Safety allegedly has a movably supported body portion. ¶59 col. 6:4-6
and an upwardly extending deflectable portion that is separately movable relative to the body portion between an extended position and a deflected position. The Super Safety allegedly has an upwardly extending "lever arm" with a "dovetail joint" that allows it to move separately from the body portion, between an extended and deflected state. ¶59 col. 6:5-9
  • Identified Points of Contention:
    • Technical Question: The complaint alleges the accused Super Safety has a "dovetail joint" that allows for separate movement of a lever arm, which it maps to the claimed "deflectable portion" (Compl. ¶59). A key technical dispute may arise over whether this dovetail joint provides the same kind of one-way "deflectable" or "folding" action described and claimed in the patent ’784 Patent, col. 2:51
    • Scope Question: The critical term is "deflectable portion that is separately movable". The court will need to determine the scope of this term. The patent specification discloses embodiments with a pivot pin and a hinge ’784 Patent, Fig. 2 ’784 Patent, Fig. 8 The question will be whether the accused dovetail joint mechanism is equivalent to, and thus covered by, the claim language.

V. Key Claim Terms for Construction

  • Patent: '247 Patent

    • The Term: "forced reset semi-automatic mode" (from claim 15)
    • Context and Importance: This term defines the novel operational state of the invention. The infringement case rests on proving the accused products operate in a mode that meets this definition, distinguishing it from a standard semi-automatic mode. Practitioners may focus on this term because the claim recites a highly specific sequence of mechanical events that constitute this "mode."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The abstract and summary describe the invention in general terms as a mechanism where "rearward movement of the bolt carrier causes rearward pivoting of the hammer and pivoting of the cam... such that a cam lobe forces the trigger member to the set position" ’247 Patent, abstract This broader functional description could support an interpretation covering various ways a cam forces a reset.
      • Evidence for a Narrower Interpretation: Claim 15 itself provides a detailed, step-by-step definition, requiring that in this mode, "rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook" ’247 Patent, claim 15 This suggests a narrow construction where the prevention of the disconnector's engagement is a required step, not just an incidental outcome of the reset.

  • Patent: '784 Patent

    • The Term: "upwardly extending deflectable portion that is separately movable" (from claim 1)
    • Context and Importance: This term describes the core novel feature intended to provide cross-platform compatibility. The infringement analysis for the ’784 patent will likely turn on whether the accused device's lever arm, allegedly connected by a "dovetail joint" (Compl. ¶59), meets this definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The Summary of the Invention states the invention provides a "deflectable extension... that deflects or folds" (’784 Patent, col. 2:49-52). The specification also describes an alternative embodiment with a hinge ’784 Patent, Figs. 8-10 This language may support a broader interpretation encompassing any mechanism that yields in one direction, including the alleged dovetail joint.
      • Evidence for a Narrower Interpretation: The primary embodiment shows a distinct component (22) that "pivots on... a transverse pivot pin 24 relative to the locking bar body 26" ’784 Patent, col. 4:40-42 This, along with the term "separately movable," could be argued to require a distinct, pivoting or hinged part, potentially excluding a more integrated joint like a dovetail connection if its movement is not truly "separate."

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Defendants induce infringement by providing customers with instructions, such as the "Super Safety Guide," and by encouraging, advertising, and promoting the use of the accused products Compl. ¶46 Compl. ¶62 It further alleges contributory infringement on the basis that Defendants sell components, such as the "cam or cam lever arm," that are "specially designed and adapted" for an infringing purpose and are "not suitable for substantial noninfringing use" Compl. ¶48 Compl. ¶64
  • Willful Infringement: Plaintiffs allege that Defendants "have known or should have known" that their actions infringe the asserted patents, which are presumed valid Compl. ¶49 Compl. ¶65 The complaint claims that despite this knowledge, Defendants have engaged in "egregious infringement behavior" and continued their infringing activities, supporting a claim for willful infringement Compl. ¶49 Compl. ¶65 Compl. ¶79

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

  • A central issue will be one of mechanical equivalency: Do the accused products operate using the specific, multi-step mechanical sequences recited in the claims? For instance, does the accused "forced reset" mode function by using a cam to force the trigger to reset while a safety selector simultaneously prevents the disconnector from engaging the hammer, as detailed in claims like '247 claim 15? The resolution will depend on a factual comparison of the accused products' operation against the patent's detailed functional language.
  • A key question of claim scope will concern the ’784 patent: can the term "deflectable portion that is separately movable," which is disclosed in the patent as a pivot or hinge, be construed to cover the "dovetail joint" allegedly used in the accused Super Safety? This will require the court to determine the breadth of "deflectable" and "separately movable" in the context of the patent's specification.
  • The case also presents a question of liability for combination: As the accused products are primarily sold as kits for end-user installation, the court will need to examine the evidence supporting indirect infringement. A key determination will be whether the components sold by Defendants are staple articles of commerce or are instead material components of the patented invention with no substantial non-infringing use, which would be critical for the contributory infringement claim.