Rare Breed Triggers Inc v. Midnight Arsenal Box LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Abc IP, LLC (Delaware) and Rare Breed Triggers, INC. (Texas)
  • Defendant: Midnight Arsenal Box LLC (Wyoming) and Zack Rosenquest (Wyoming)
  • Plaintiff's Counsel: Koch Law, P.C.
• Case Identification: 4:26-cv-01130, D. Wyo., 06/17/2026
• Venue Allegations: Venue is alleged to be proper in the District of Wyoming because Defendants reside in the district, have a regular and established place of business there, and have committed alleged acts of infringement within the district.
• Core Dispute: Plaintiffs allege that Defendants' "Atrius Forced Reset Selector" product infringes four patents related to selectable-mode, forced-reset firearm trigger mechanisms.
• Technical Context: The technology involves aftermarket firearm components designed to increase the rate of semi-automatic fire by using the firearm's cycling action to mechanically reset the trigger, a feature with notable interest in the commercial firearms market.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history relevant to the asserted patents.

Case Timeline

Date	Event
2021-11-05	Priority Date for U.S. Patent No. 12,031,784
2022-01-10	Priority Date for U.S. Patent No. 12,636,403
2022-09-08	Priority Date for U.S. Patent No. 12,038,247
2022-09-08	Priority Date for U.S. Patent No. 12,578,159
2024-07-09	U.S. Patent No. 12,031,784 Issued
2024-07-16	U.S. Patent No. 12,038,247 Issued
2026-03-17	U.S. Patent No. 12,578,159 Issued
2026-05-26	U.S. Patent No. 12,636,403 Issued
2026-06-17	Complaint Filed

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

U.S. Patent No. 12,038,247 - Firearm Trigger Mechanism, issued July 16, 2024

The Invention Explained

• Problem Addressed: The patent's background describes a desire among firearm users to increase the rate of semi-automatic fire, noting that standard trigger mechanisms limit this rate and that alternative methods like "bump firing" can be difficult to master ʼ247 Patent, col. 1:38-56
• The Patented Solution: The invention is a "drop-in" trigger module for AR-pattern firearms that provides a "three position" selector for "safe, standard semi-automatic, and forced reset semi-automatic positions" ʼ247 Patent, col. 2:25-30 In the forced reset mode, a cam, which is pivoted by the rearward movement of the bolt carrier, forces the trigger member back to its set position, allowing for a more rapid subsequent shot ʼ247 Patent, abstract ʼ247 Patent, col. 3:1-11
• Technical Importance: The technology offers a retrofittable module that allows a user to select between a conventional semi-automatic rate of fire and an accelerated, mechanically assisted rate of fire ʼ247 Patent, col. 2:18-25

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 15 Compl. ¶31
• The essential elements of independent claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, a cam, and a safety selector.
  • The mechanism is operable in a "standard semi-automatic mode" where, after firing, a user must manually release the trigger to reset the hammer from the disconnector.
  • The mechanism is also operable in a "forced reset semi-automatic mode" where rearward movement of the bolt carrier causes the cam to force the trigger member to its set position, and the disconnector hook is prevented 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. ¶31

U.S. Patent No. 12,031,784 - Adapted Forced Reset Trigger, issued July 9, 2024

The Invention Explained

• Problem Addressed: The patent identifies an incompatibility issue where forced reset triggers designed for AR-15 platforms may not function in AR-10 platforms due to different bolt carrier dimensions, which can cause the bolt carrier to interfere with the trigger's locking member during its rearward cycle ʼ784 Patent, col. 1:21-44
• The Patented Solution: The invention provides a trigger locking device with an "upwardly extending deflectable portion" '784 Patent, claim 1 This extension is long enough to be actuated by the AR-10 bolt carrier upon returning to battery, but it is designed to "deflect or fold" out of the way when the bolt carrier cycles rearward, thus avoiding the interference that would otherwise render the device inoperable ('784 Patent, col. 2:45-52; '784 Patent, Fig. 7).
• Technical Importance: This design adapts forced reset trigger technology for use in a different class of firearms (AR-10 pattern) by overcoming specific geometric and operational conflicts ʼ784 Patent, col. 1:12-14

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶45
• 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.
  • The locking member has a "movably supported" body portion and an "upwardly extending deflectable portion that is separately movable relative to the body portion" between an extended and a deflected position.
  • Contact from the bolt carrier causes the locking member to move from the first to the second position.
• The complaint reserves the right to assert other claims Compl. ¶45

U.S. Patent No. 12,578,159 - Firearm Trigger Mechanism, issued March 17, 2026

• Technology Synopsis: The patent discloses a firearm trigger mechanism operable in both a standard semi-automatic mode and a forced reset semi-automatic mode '159 Patent, abstract The invention uses a cam actuated by the firearm's reciprocating bolt to force the trigger to reset, enabling an increased rate of fire in the forced reset mode Compl. ¶21 '159 Patent, abstract
• Asserted Claims: Independent claim 1 Compl. ¶59
• Accused Features: The complaint alleges that the Atrius Selector, which provides both standard and forced reset modes, infringes by embodying the claimed multi-mode trigger mechanism Compl. ¶¶59-61

U.S. Patent No. 12,636,403 - Firearm Trigger Mechanism, issued May 26, 2026

• Technology Synopsis: The patent describes a trigger mechanism with a safety selector that allows a user to choose between a standard semi-automatic mode and a forced reset semi-automatic mode Compl. ¶23 In the forced reset mode, the safety selector mechanically prevents the disconnector from catching the hammer, which, in conjunction with other components, forces the trigger to reset upon the action cycling '403 Patent, abstract
• Asserted Claims: Independent claim 38 Compl. ¶73
• Accused Features: The Atrius Selector is accused of infringing by functioning as a safety selector that is movable between a standard semi-automatic position and a forced reset semi-automatic position, thereby embodying the claimed invention Compl. ¶¶73-75

III. The Accused Instrumentality

Product Identification

The accused product is the "(3-Position) 'Atrius Forced Reset Selector'" (the "Atrius Selector") Compl. ¶26

Functionality and Market Context

• The Atrius Selector is an aftermarket firearm component that allegedly allows a user to switch between safe, standard semi-automatic, and forced reset semi-automatic modes by rotating the selector Compl. ¶29 In the forced reset mode, the cycling of the firearm's action forces the trigger to reset, enabling a higher rate of fire than a standard trigger Compl. ¶20 Compl. ¶29
• Defendants are alleged to offer the Atrius Selector for sale through a commercial website, both as a standalone product and in conjunction with other trigger mechanism parts Compl. ¶27 The complaint includes a screenshot from the Defendants' website showing various product listings for the Atrius Selector, including a promotional package titled "Midnight MP5 Madness" Compl. ¶28, p. 8 This image shows the Atrius Selector marketed as part of a kit.

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 Atrius Selector is installed with a hammer that has a sear catch and a hook for engaging a disconnector.	¶33	col. 7:45-53
a trigger member having a sear...	The Atrius Selector is installed with a trigger member that has a sear.	¶33	col. 7:54-59
a disconnector having a hook for engaging said hammer...	The Atrius Selector is installed with a disconnector that has a hook for engaging the hammer.	¶33	col. 8:1-4
and a cam having a cam lobe...	The Atrius Selector has a cam with a cam lobe. The complaint provides a plaintiff-generated rendering of the "Atrius Super Selector Cam with Lobe and Lever" Compl. ¶33, p. 15	¶33	col. 8:5-9
whereupon in a standard semi-automatic mode, ... a user must manually release said trigger member to free said hammer from said disconnector...	In standard semi-automatic mode, the user must manually release the trigger to free the hammer from the disconnector, allowing the trigger to reset.	¶33	col. 9:22-29
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,	In forced reset mode, the cam is in a second position, and rearward movement of the bolt carrier pivots the hammer such that the disconnector hook is prevented from catching it.	¶33	col. 9:30-41
at which time the user can pull said trigger member to fire the firearm.	At this point, the user can pull the trigger to fire the firearm again without having manually released it.	¶33	col. 9:55-61

Identified Points of Contention

• Scope Question: A central question may be whether the operation of the Atrius Selector in its "forced reset" mode meets the specific negative limitation that the "disconnector hook is prevented from catching said hammer hook." The evidence and mechanism for this prevention will be a key point of analysis.
• Technical Question: The complaint's infringement theory relies on plaintiff-generated renderings of the accused product's internal operations Compl. ¶33, p. 12 A point of contention will be whether these renderings accurately depict the actual function and interaction of the components within the commercial Atrius Selector product.

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...	The Atrius Selector is alleged to be part of a forced reset trigger and functions as a locking device, movable between a locked first position and an unlocked second position.	¶47	col. 2:53-59
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 Atrius Selector allegedly has a body portion and an upwardly extending "lever arm" that serves as the deflectable portion. This lever arm is alleged to be separately movable between an extended and a deflected position. A plaintiff-generated rendering shows this separate movement Compl. ¶47, p. 28	¶47	col. 2:60-65
such actuating contact causing the locking member to move from the first position to the second position,	Contact from the bolt carrier is alleged to actuate the locking member, causing it to move from the locked to the unlocked position.	¶47	col. 2:1-4

Identified Points of Contention

• Scope Question: A primary focus of the dispute will likely be the claim term "upwardly extending deflectable portion that is separately movable relative to the body portion." The court will need to determine if the accused "lever arm" Compl. ¶47, p. 26 falls within the scope of this term, which was invented to solve a specific AR-10 compatibility problem.
• Technical Question: The complaint alleges the connection in the Atrius Selector is "designed to allow separate movement of the lever arm" Compl. ¶47, p. 28 The factual basis for this "design" and the actual degree of separate movement in the accused product, compared to the movement described in the patent's embodiments, will be a central technical question.

V. Key Claim Terms for Construction

From the '247 Patent

• The Term: "disconnector hook is prevented from catching said hammer hook" (claim 15)
• Context and Importance: This negative limitation is a defining characteristic of the claimed "forced reset semi-automatic mode." Whether the accused device achieves this "prevention" and the mechanism by which it does so will be critical to the infringement analysis. The patent distinguishes this mode from the "standard" mode where the disconnector explicitly catches the hammer.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is functional, stating only that the hook is "prevented" from catching. This could be read to cover any mechanism that achieves this result, whether by physical blocking, timing, or displacement.
  • Evidence for a Narrower Interpretation: The specification describes the safety selector having a "narrow semi-circular portion" (116) that "prevents the disconnector 60 from pivoting," thus preventing the catch '247 Patent, col. 8:55-64 Parties may argue this specific embodiment limits the scope of "prevented" to the action of the safety selector physically impeding the disconnector's movement.

From the '784 Patent

• The Term: "separately movable relative to the body portion" (claim 1)
• Context and Importance: This is the key feature that allegedly adapts the trigger for different firearm platforms. The entire infringement allegation for this patent hinges on whether the accused product's lever arm is "separately movable" in the way the patent claims. Practitioners may focus on this term because it is the stated point of novelty for overcoming prior art limitations.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the invention "provides a deflectable extension" that "deflects or folds" ('784 Patent, col. 2:45-49), suggesting the term could cover a variety of hinged, pivoting, or even flexible structures that allow independent movement.
  • Evidence for a Narrower Interpretation: The embodiments shown in Figures 2-7 and 8-10 depict specific pivoting mechanisms using a pivot pin (24, 54) and, in one embodiment, a spring (28) '784 Patent, col. 3:42-46 '784 Patent, col. 4:38-44 A defendant may argue that "separately movable" should be construed to require a distinct, hinged mechanical structure as shown, rather than mere flexing of a single component.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents. The inducement allegations are based on Defendants allegedly "encouraging, advertising, promoting, and instructing others to use and/or how to use the Atrius Selector" Compl. ¶34 Compl. ¶48 Compl. ¶62 Compl. ¶76 The contributory infringement allegations assert that the components of the Atrius Selector are "specially designed and adapted" for use in an infringing manner and are "not suitable for substantial noninfringing use" Compl. ¶36 Compl. ¶50 Compl. ¶64 Compl. ¶78
• Willful Infringement: The complaint alleges willful infringement for all four patents, asserting that Defendants "have known or should have known" their actions constituted infringement and that they "could not reasonably or subjectively believe" the patents were invalid or not infringed Compl. ¶37 Compl. ¶51 Compl. ¶65 Compl. ¶79 The allegations are based on knowledge at least as of the service of the complaint.

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

• A core issue will be one of definitional scope: can the term "separately movable... deflectable portion," rooted in the '784's context of solving an AR-10 compatibility problem, be construed to read on the "lever arm" of the accused Atrius Selector, which is marketed for use in MP5-pattern firearms?
• A key question of functional interpretation will permeate the case across all four patents: does the accused product's operation in its "forced reset" mode align with the specific sequence of mechanical events claimed-particularly the interaction between the cam, the trigger, and the disconnector-or is there a fundamental mismatch in the method of operation?
• An evidentiary question will concern indirect infringement: what specific evidence will Plaintiffs present to show that Defendants' marketing and instructions actively induced customers to use the Atrius Selector in a way that infringes the particular steps recited in the patent claims, beyond simply encouraging the general use of a forced-reset trigger?