ABC IP LLC v. Velocity Ammunition Sales LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware); Rare Breed Triggers, Inc. (Texas); RBTM LLC (Wyoming)
  • Defendant: Velocity Ammunition Sales, LLC (Virginia); David Allen Hazlett (Virginia)
  • Plaintiff's Counsel: Fish & Richardson P.C.
• Case Name: ABC IP, LLC v. Velocity Ammunition Sales, LLC
• Case Identification: 3:26-cv-00533, E.D. Va., 06/09/2026
• Venue Allegations: Venue is alleged to be proper as Defendants reside in the district and have committed alleged acts of infringement and maintain a regular and established place of business within the district.
• Core Dispute: Plaintiffs allege that Defendants' "Disruptor" trigger assembly for AR-15 pattern firearms infringes five U.S. patents related to "forced reset" trigger mechanisms that use the firearm's cycling action to reset the trigger.
• Technical Context: The technology concerns aftermarket trigger mechanisms for semi-automatic firearms, designed to increase the potential rate of fire by altering the standard trigger reset process.
• Key Procedural History: The complaint alleges that the manufacturer of the accused product hosts a webpage linking to three of the asserted patents, which Plaintiffs may use to argue pre-suit knowledge for their willfulness claim.

Case Timeline

Date	Event
2017-09-29	Priority Date for '223 Patent
2019-12-24	'223 Patent Issued
2020-01-01	Plaintiffs allege use of "FRT" mark since at least 2020
2022-01-10	Priority Date for '003, '336, '807, and '403 Patents
2023-08-15	'003 Patent Issued
2024-07-16	'336 Patent Issued
2025-04-15	'807 Patent Issued
2026-05-26	'403 Patent Issued
2026-06-09	Complaint Filing Date

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

U.S. Patent No. 10,514,223, "Firearm Trigger Mechanism" (Issued: December 24, 2019)

The Invention Explained

• Problem Addressed: The patent background describes that standard semi-automatic triggers limit the rate of fire because a user must manually release the trigger to reset the disconnector before firing again ʼ223 Patent, col. 1:25-34 Prior methods to increase firing rate, such as "bump firing," were described as techniques used by shooters to achieve this effect, while other mechanical solutions were noted as being complex or expensive ʼ223 Patent, col. 1:41-54
• The Patented Solution: The invention is a "forced reset" trigger mechanism, designed as a "drop-in" module for firearms like the AR-15 ʼ223 Patent, col. 2:30-34 During the firearm's cycle of operation, the rearward movement of the bolt carrier pushes the hammer back, and the hammer in turn makes contact with the trigger member, forcing it back to its set (reset) position ʼ223 Patent, abstract ʼ223 Patent, col. 5:28-37 A "locking bar" then mechanically blocks the trigger from being pulled again until the bolt carrier has returned to its "substantially in-battery" position, preventing out-of-battery firing or "hammer follow" ʼ223 Patent, col. 4:1-12
• Technical Importance: This design provides a mechanical method to increase the potential semi-automatic rate of fire in a self-contained module that can be easily installed in common firearm platforms.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 4, an independent claim Compl. ¶46
• Claim 4 of the '223 Patent recites the following primary elements:
  • A housing with openings for hammer and trigger assembly pins.
  • A hammer with a sear notch, mounted in the housing.
  • A trigger member with a sear, mounted in the housing, having a surface positioned to be contacted by the hammer when cycled, causing the trigger member to be "forced to the set position."
  • A locking bar pivotally mounted in the housing, which is spring-biased toward a first position where it "mechanically blocks the trigger member."
  • The locking bar is movable to a second, non-blocking position when contacted by the bolt carrier upon reaching a "substantially in-battery position," allowing the trigger to be moved by an external force.
• The complaint reserves the right to assert other claims Compl. ¶46

U.S. Patent No. 11,724,003, "Firearm Trigger Mechanism" (Issued: August 15, 2023)

The Invention Explained

• Problem Addressed: The patent seeks to provide further improvement in forced reset triggers, building upon prior designs ʼ003 Patent, col. 2:19-22
• The Patented Solution: The patent describes a trigger mechanism with three user-selectable modes: safe, standard semi-automatic, and forced reset semi-automatic ʼ003 Patent, abstract A three-position safety selector controls the mode. In "standard" mode, a traditional disconnector catches the hammer, requiring the user to release the trigger to reset it ʼ003 Patent, col. 9:22-37 In "forced reset" mode, the cycling of the bolt carrier forces the trigger to reset, and the safety selector repositions the disconnector to prevent it from catching the hammer, allowing for a subsequent shot without the user releasing the trigger ʼ003 Patent, col. 9:48-60
• Technical Importance: This invention provides user-selectable functionality, combining a conventional semi-automatic trigger operation with a rapid-fire "forced reset" capability within a single, integrated mechanism.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 4, an independent claim Compl. ¶60
• Claim 4 of the '003 Patent recites the following primary elements:
  • A firearm trigger mechanism comprising a housing, hammer, trigger member, disconnector, and locking member.
  • A safety selector adapted to pivot between "safe, standard semi-automatic, and forced reset semi-automatic positions."
  • A "whereupon" clause describing operation in the standard semi-automatic position, where the disconnector catches the hammer hook and the user "must manually release said trigger member" to fire again.
  • A "whereupon" clause describing operation in the forced reset position, where rearward movement of the bolt carrier forces the trigger to its set position, the safety selector prevents the disconnector from catching the hammer, and the user can subsequently fire "without manually releasing said trigger member."
• The complaint reserves the right to assert other claims Compl. ¶60

Multi-Patent Capsule: U.S. Patent No. 12,036,336

• Patent Identification: U.S. Patent No. 12,036,336, "Firearm Trigger Mechanism," Issued July 16, 2024 Compl. ¶13
• Technology Synopsis: The patent describes a trigger mechanism for AR-pattern firearms that features a three-position safety selector for "safe, standard semi-automatic, and forced reset semi-automatic positions." The invention allows a user to choose between a conventional trigger operation requiring a manual reset and a forced-reset operation for a higher rate of fire '336 Patent, abstract
• Asserted Claims: Independent claim 3 Compl. ¶74
• Accused Features: The complaint alleges that the Disruptor product, including its housing, hammer, trigger, disconnector, locking member, and three-position safety selector, infringes by providing both standard and forced reset semi-automatic modes Compl. ¶76

Multi-Patent Capsule: U.S. Patent No. 12,274,807

• Patent Identification: U.S. Patent No. 12,274,807, "Firearm Trigger Mechanism," Issued April 15, 2025 Compl. ¶14
• Technology Synopsis: The patent discloses a firearm trigger mechanism with a selectable firing mode system. It includes a hammer, trigger member, disconnector, locking member, and a three-position safety selector to switch between standard semi-automatic and forced reset semi-automatic operation, enabling both conventional and rapid-fire capabilities '807 Patent, abstract
• Asserted Claims: Independent claim 1 Compl. ¶88
• Accused Features: The complaint accuses the Disruptor's integrated trigger mechanism, which allegedly incorporates all claimed elements (hammer, trigger, disconnector, locking member, and three-position selector) to provide selectable firing modes Compl. ¶90

Multi-Patent Capsule: U.S. Patent No. 12,636,403

• Patent Identification: U.S. Patent No. 12,636,403, "Firearm Trigger Mechanism," Issued May 26, 2026 Compl. ¶15
• Technology Synopsis: The patent describes a forced reset trigger mechanism comprising a hammer, disconnector, trigger member, and a safety selector. The invention details the interaction where, in the forced reset mode, the safety selector prevents the disconnector from catching the hammer, allowing the user to fire again without manually releasing the trigger after it has been forcibly reset by the action '403 Patent, abstract
• Asserted Claims: Independent claim 38 Compl. ¶102
• Accused Features: The complaint accuses the Disruptor's hammer, disconnector, trigger member, and safety selector of infringing by operating in both a standard mode, where trigger pressure must be reduced, and a forced reset mode Compl. ¶104

III. The Accused Instrumentality

• Product Identification: The accused product is the "Partisan Triggers - Disruptor AR-15 Forced Reset Trigger" (the "Disruptor") Compl. ¶26
• Functionality and Market Context: The Disruptor is an aftermarket trigger assembly for AR-15 pattern firearms Compl. ¶26 According to the complaint, it operates in multiple modes selected via a three-position safety selector: a standard semi-automatic "disconnector mode" and a "forced reset semiautomatic" mode Compl. ¶¶29, 30 In the forced reset mode, the cycling of the firearm's action is alleged to cause "hammer contact with the trigger member to forcefully reset the hammer and trigger member" Compl. ¶30 A "locking bar/member" allegedly prevents the trigger from being pulled until the bolt carrier is in battery Compl. ¶30 The complaint includes a screenshot from the manufacturer's website identifying Defendant Velocity as an authorized dealer of the Disruptor Compl. ¶34 Another screenshot from the product page shows the Disruptor trigger assembly and its component parts Compl. ¶28

IV. Analysis of Infringement Allegations

10,514,223 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a housing having transversely aligned pairs of openings for receiving hammer and trigger assembly pins;	The Disruptor includes a housing with transversely aligned pairs of openings for receiving hammer and trigger assembly pins.	¶48	col. 3:35-46
a hammer having a sear notch and mounted in the housing to pivot on a transverse axis between set and released positions;	The Disruptor includes a hammer with a sear notch and is mounted in the housing to pivot on a transverse axis.	¶48	col. 3:47-50
a trigger member having a sear and mounted in the housing to pivot on a transverse axis between set and released positions,	The Disruptor has a trigger member that has a sear and is mounted in a housing to pivot on a transverse axis.	¶48	col. 4:1-4
the trigger member having a surface positioned to be contacted by the hammer when the hammer is displaced by the bolt carrier when cycled, the contact causing the trigger member to be forced to the set position;	The trigger member has a surface positioned to be contacted by a surface of the hammer, and the contact causes the trigger member to be forced to the set position. The complaint provides a plaintiff-generated diagram illustrating this alleged interaction Compl. p. 18	¶48	col. 5:32-37
a locking bar pivotally mounted in the housing and spring biased toward a first position in which the locking bar mechanically blocks the trigger member from moving to the released position,	The Disruptor includes a locking bar that is pivotally mounted in the housing and is spring biased toward a first position where it mechanically blocks the trigger member.	¶48	col. 3:61-63
and movable against the spring bias to a second position when contacted by the bolt carrier reaching a substantially in-battery position in which the trigger member can be moved by an external force to the released position.	The locking bar is movable against the spring bias to a second position when contacted by the bolt carrier, allowing the trigger member to be moved by an external force (a pull by the trigger finger).	¶48	col. 6:55-63

11,724,003 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a safety selector adapted to be mounted in a fire control mechanism pocket of a receiver to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Disruptor includes a safety selector that is mounted in a receiver to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions. The complaint includes a photo identifying the safety selector part Compl. p. 32	¶62	col. 9:11-15
whereupon in said standard semi-automatic position, 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 to free said hammer...	In the standard semi-automatic position, rearward movement of the bolt carrier causes the hammer to pivot and the disconnector hook catches the hammer hook, requiring the user to manually release the trigger.	¶62	col. 9:22-37
whereupon in said forced reset semi-automatic position, rearward movement of the bolt carrier causes rearward pivoting of said hammer causing said trigger member to be forced to said set position,	When in the forced reset semi-automatic position, rearward movement of the bolt carrier causes the hammer to pivot, which causes the trigger to be forced to the set position.	¶62	col. 9:48-54
said safety selector preventing said disconnector hook from catching said hammer hook,	The safety selector prevents the disconnector hook from catching the hammer hook.	¶62	col. 9:54-57
and thereafter when the bolt carrier reaches the substantially in-battery position the user can pull said trigger member to fire the firearm without manually releasing said trigger member.	When the bolt carrier reaches a substantially in-battery position, the user can pull the trigger without manually releasing pressure off the trigger.	¶62	col. 9:57-62

• Identified Points of Contention:
  • Technical Questions: The complaint presents the accused Disruptor as a direct implementation of the patented technology, supported by plaintiff-generated color-coded diagrams of the accused product's internal mechanism Compl. pp. 15-20 Compl. pp. 24-34 A central question for the court will be an evidentiary one: does the actual mechanical operation of the Disruptor-particularly the geometry and interaction of its hammer, trigger, locking bar, and selector components-match the functions and structures as claimed, or are there material differences not apparent from the complaint's diagrams?
  • Scope Questions: The claims in the later patents ('003, '336, etc.) recite a specific sequence of operations for both "standard" and "forced reset" modes. The infringement analysis may turn on whether the Disruptor's "disconnector mode" and "forced reset mode" Compl. ¶29 function precisely as described in the "whereupon" clauses of the asserted claims, raising the question of whether there is any functional or sequential deviation that would place the accused product outside the literal scope of the claims.

V. Key Claim Terms for Construction

• The Term: "forced to the set position" (present in claims of both '223 and '003 Patents)

  • Context and Importance: This term defines the core inventive concept of a "forced reset." Its construction is critical because it distinguishes the invention from standard trigger mechanisms where the user must release the trigger to achieve reset. Practitioners may focus on this term to dispute whether the accused product's reset action is caused by the specific "forcing" contact described in the patent or by some other means.
  • Intrinsic Evidence for Broader Interpretation: The specification of the '223 Patent states that "contact between a rear surface 74 of the hammer 18...and a contact surface 30 of the trigger member 26 forces the trigger to pivot...toward and to its reset position," suggesting any such contact causing the reset could fall within the term's scope ʼ223 Patent, col. 5:32-37
  • Evidence for a Narrower Interpretation: Parties may point to the specific embodiments and figures (e.g.,'223 Patent, Fig. 5), arguing that "forced" implies a specific type of non-incidental, positive mechanical action rather than any contact that results in a reset.

• The Term: "locking bar" (present in claims of both '223 and '003 Patents)

  • Context and Importance: This element is the primary safety feature preventing out-of-battery firing in the forced-reset design. Its definition will be central to determining infringement, as any structural or functional difference in the accused product's safety mechanism will be heavily scrutinized.
  • Intrinsic Evidence for Broader Interpretation: The claims functionally define the element as a bar that "mechanically blocks the trigger member" and is moved to a non-blocking position "when contacted by the bolt carrier" '223 Patent, cl. 4 This functional language could support an interpretation that covers any component performing this specific blocking and unblocking sequence, regardless of its exact shape or mounting.
  • Evidence for a Narrower Interpretation: The specification discloses a "locking bar 62 carried on a frame 66 for pivotal movement on a transverse pivot pin 68" '223 Patent, col. 3:61-63 A defendant could argue this disclosure limits the term to a pivotally mounted bar, potentially excluding other structures like a sliding or non-pivoting block that achieves a similar function.

• The Term: "substantially in-battery position" (present in claims of both '223 and '003 Patents)

  • Context and Importance: This term dictates the precise timing for when the trigger is unblocked and can be fired again. The meaning of "substantially" is a frequent subject of claim construction and will be critical in determining whether the timing of the accused product's safety release falls within the claim scope.
  • Intrinsic Evidence for Broader Interpretation: The patent states the purpose is to prevent contact of the hammer with the firing pin "before the bolt is completely locked and in-battery," suggesting the term could broadly cover any point in the cycle where firing is safe '223 Patent, col. 6:64-67
  • Evidence for a Narrower Interpretation: The '223 Patent specification provides a potential range, stating the trigger may be manually displaced for "about from about 0.10 to 0.31 inch" of bolt carrier travel before it is fully in battery '223 Patent, col. 6:57-61 This language could be used to argue for a more defined, measurable window for what constitutes a "substantially in-battery position."

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement.
  • Inducement is premised on Defendants' alleged knowledge of the patents and acts of "encouraging, advertising, promoting, and instructing others to use" the Disruptor, specifically citing website promotional material and installation instructions for an AR-15 Compl. ¶¶49-50 Compl. ¶77 Compl. p. 21
  • Contributory infringement is based on the allegation that the Disruptor's components are "not suitable for substantial noninfringing use" because they are "specially designed and adapted to be used in a fire control unit to forcibly reset a trigger mechanism" Compl. ¶51 Compl. ¶65
• Willful Infringement: Willfulness is alleged based on pre-suit knowledge of Plaintiffs' patent rights. The complaint alleges that the manufacturer of the Disruptor maintains a webpage titled "FRT Legal Library" that links to copies of the '223, '003, and '336 patents, and that Defendants, as an authorized dealer, had access to and knowledge of this information Compl. ¶¶33-35

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

• A central factual question will be one of evidentiary proof: Will discovery show that the internal mechanism of the accused "Disruptor" trigger operates in a manner identical to the functions and structures recited in the claims, as the complaint's diagrams suggest, or will it reveal material technical distinctions in how the device achieves its "forced reset" and "locking" functions?
• A core issue of claim scope for the later patents will be: Can the "whereupon" clauses detailing the specific operational sequences for "standard" and "forced reset" modes be met by the accused product, or is there a functional or timing variance in the Disruptor's mode-switching that places it outside the literal scope of the claims?
• A key question for willfulness will be one of imputed knowledge: Will the allegation that the manufacturer hosted a "Legal Library" with links to the patents be sufficient to prove that the reseller Defendant possessed the requisite pre-suit knowledge and formed the specific intent necessary to support a finding of willful and induced infringement?