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 (individual)
  • Plaintiff's Counsel: Koch Law, P.C.
• Case Identification: 1:26-cv-00190, D. Wyo., 06/17/2026
• Venue Allegations: Venue is alleged to be proper in the District of Wyoming because Defendants reside in the district and have a regular and established place of business there.
• Core Dispute: Plaintiff alleges that Defendant's "Atrius Forced Reset Selector" infringes four U.S. patents related to forced reset trigger mechanisms for semi-automatic firearms.
• Technical Context: The technology involves firearm trigger mechanisms designed to increase the potential rate of semi-automatic fire by using the firearm's cycling action to mechanically reset the trigger.
• Key Procedural History: The complaint does not allege any significant procedural history, such as prior litigation between the parties, Inter Partes Review (IPR) proceedings, or prior licensing of the patents-in-suit.

Case Timeline

Date	Event
2021-11-05	'784 Patent Priority Date
2022-01-10	'403 Patent Priority Date
2022-09-08	'247 and '159 Patents Priority Date
2024-07-09	'784 Patent Issue Date
2024-07-16	'247 Patent Issue Date
2026-03-17	'159 Patent Issue Date
2026-05-26	'403 Patent 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 Invention Explained

• Problem Addressed: In a standard semi-automatic firearm, the trigger must be manually released after each shot to reset the internal mechanism (the sear) before another shot can be fired, which limits the rate of fire Compl. ¶¶18-19 Shooters, however, often desire to increase this rate of fire '247 Patent, col. 1:41-43
• The Patented Solution: The invention is a trigger mechanism, often constructed as a "drop-in" module, that includes a "forced reset" mode selectable by the user '247 Patent, col. 2:23-27 When in this 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 reset position '247 Patent, abstract This allows the user to fire the next shot without needing to manually release and reset the trigger, thereby enabling a much faster firing sequence Compl. ¶21
• Technical Importance: This technology offers a way to significantly increase the firing speed of common semi-automatic platforms like AR-15-style firearms, providing an experience that can approach that of a fully automatic firearm while operating under a semi-automatic legal framework.

Key Claims at a Glance

• The complaint asserts independent claim 15 Compl. ¶31
• The essential elements of claim 15 include:
  • A firearm trigger mechanism comprising a hammer, a trigger member, a disconnector, and a cam.
  • The cam is movable between a first position (for standard semi-automatic mode) and a second position (for forced reset mode).
  • In the standard mode, the user must manually release the trigger to free the hammer from the disconnector to fire again.
  • In the forced reset mode, the cam lobe "forces said trigger member towards said set position."
  • In the forced reset mode, the rearward movement of the bolt carrier causes the disconnector hook to be "prevented from catching said hammer hook."
• The complaint reserves the right to assert additional 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's background explains that prior art forced reset triggers designed for one firearm pattern (e.g., an AR-15) may not be operable in another pattern (e.g., an AR-10) due to different bolt carrier geometries '784 Patent, col. 1:20-32 Specifically, extending a trigger locking bar to be actuated by the AR-10's bolt carrier could cause it to interfere with another part of that same carrier as it cycles, making the device inoperable '784 Patent, col. 1:36-44
• The Patented Solution: The invention provides an "extended trigger member locking device" that has a "separately movable" and "deflectable portion" '784 Patent, claim 1 This upward-extending portion is designed with a one-way hinge, allowing it to fold out of the way when the forward part of the bolt carrier passes over it during rearward cycling, but remain rigid enough to be actuated by the rear part of the bolt carrier as it returns to battery '784 Patent, abstract '784 Patent, col. 2:46-53
• Technical Importance: This design enhances the modularity of forced reset triggers, allowing a single core design to be adapted for use in a wider variety of semi-automatic firearms with different internal geometries without causing interference or malfunction.

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶45
• The 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."
  • The deflectable portion is "separately movable relative to the body portion" between an extended and a deflected position.
• The complaint reserves the right to assert additional claims Compl. ¶45

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

• Technology Synopsis: This patent, which shares a priority claim with the '247 Patent, describes a trigger mechanism operable in both a standard semi-automatic mode and a forced reset semi-automatic mode '159 Patent, claim 1 In the forced reset mode, a cam, actuated by the firearm's bolt, forces the trigger to its reset position, allowing for a subsequent shot without the user needing to manually release the trigger '159 Patent, abstract
• Asserted Claims: The complaint asserts independent claim 1 Compl. ¶59
• Accused Features: The complaint alleges that the Atrius Selector, with its dual-mode functionality, infringes the '159 Patent Compl. ¶26 Compl. ¶59

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

• Technology Synopsis: The complaint states this patent describes a "similarly operating device" that can be selected to operate in either a standard disconnector semi-automatic mode or a forced reset semi-automatic mode Compl. ¶23 The invention uses a safety selector to control the operational mode, and in the forced reset mode, the hammer's interaction with the trigger member forces a reset without requiring the user to release the trigger '403 Patent, abstract
• Asserted Claims: The complaint asserts independent claim 38 Compl. ¶73
• Accused Features: The Atrius Selector is accused of infringing by embodying a mechanism that is selectable between standard and forced reset modes Compl. ¶23 Compl. ¶73

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

The Atrius Selector is a firearm component marketed and sold by the Defendants via their website Compl. ¶27 The complaint alleges it is a forced reset trigger mechanism that can be installed in firearms to enable two distinct modes of operation: a standard semi-automatic mode using a disconnector, and a "forced reset semiautomatic with cam" mode Compl. ¶29 The user can switch between these modes by rotating the selector Compl. ¶29 Promotional material included in the complaint suggests it is marketed for MP5-pattern firearms, among others Compl. p. 7 The complaint includes a plaintiff-generated rendering of the accused selector's cam and lever, illustrating the components alleged to perform the forced reset function Compl. p. 15

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 Atrius Selector is alleged to be part of a forced reset trigger mechanism.	¶33	col. 9:1-2
...and a cam having a cam lobe and adapted to be movably mounted in the fire control mechanism pocket,	The Atrius Selector allegedly has a cam with a lobe that is movably mounted in the fire control pocket.	¶33	col. 9:22-26
said cam being movable between a first position and a second position,	The accused cam is allegedly movable between a first and second position to select the operating mode.	¶33	col. 9:39-44
in said second position said cam lobe forces said trigger member towards said set position,	In the forced reset mode, the accused cam lobe allegedly forces the trigger member back toward its set position during the operational cycle.	¶33	col. 9:45-48
whereupon in a forced reset semi-automatic mode,	When in the forced reset mode, the Atrius Selector allegedly operates as claimed.	¶33	col. 10:1-2
...rearward movement of the bolt carrier causes rearward pivoting of said hammer such that said disconnector hook is prevented from catching said hammer hook,	The complaint alleges that in the forced reset mode, the cam's action prevents the disconnector from catching the hammer hook. A plaintiff-generated diagram shows the disconnector hook not engaging the hammer hook as the hammer pivots rearward Compl. p. 19	¶33	col. 10:4-7

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
In a forced reset trigger mechanism, an extended trigger member locking device, comprising:	The Atrius Selector is alleged to be and function as an extended trigger member locking device within a forced reset trigger mechanism.	¶47	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 device allegedly operates as a locking member, with a locked first position and an unlocked second position.	¶47	col. 5:14-19
the locking member having a body portion that is movably supported	The Atrius Selector allegedly has a body portion that is movably supported by the firearm's lower receiver.	¶47	col. 6:4-5
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 is alleged to have an upwardly extending lever arm that is separately movable relative to its body. An overlay diagram in the complaint shows the lever arm deflecting independently of the body portion Compl. p. 28	¶47	col. 6:5-9

Identified Points of Contention

• Scope Questions: For the '784 Patent, a central dispute may arise over the meaning of "separately movable." The patent's primary embodiment depicts a two-piece assembly joined by a pivot pin '784 Patent, Fig. 2 The litigation may question whether the accused Atrius Selector, which the complaint depicts as having a "lever arm," meets this limitation if it is a single, flexible component rather than a distinct, hinged part.
• Technical Questions: For the '247 Patent, the infringement analysis raises the evidentiary question of whether the accused device's operation in forced reset mode actively "prevents" the disconnector from catching the hammer, as required by claim 15. The defense may argue that the mechanism operates differently, for instance, by simply out-racing the disconnector or rendering its catch functionally irrelevant without meeting the specific "prevention" limitation as claimed.

V. Key Claim Terms for Construction

For U.S. Patent No. 12,038,247

• The Term: "is prevented from catching said hammer hook" (from claim 15)
• Context and Importance: This limitation defines the unique operation of the "forced reset" mode compared to the "standard" mode. The interpretation of "prevented" is critical; it distinguishes the claimed invention from a system where the disconnector might still be able to catch the hammer but is simply bypassed by the speed of the reset. Practitioners may focus on whether this requires an active blocking or disabling of the disconnector's function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that in the forced reset position, a "narrow semi-circular portion 116 permits the trigger blade 54 to be pulled but prevents the disconnector 60 from pivoting with the trigger member 38" '247 Patent, col. 8:60-64 This could be argued to support any mechanism that stops the disconnector from functioning as intended, regardless of the specific means.
  • Evidence for a Narrower Interpretation: The specification also describes this action by stating the "safety selector preventing the disconnector hook from catching the hammer hook" '247 Patent, abstract This language, tying the prevention directly to the safety selector's state, could support a narrower interpretation requiring a specific interaction with the selector itself, rather than just a consequence of the cam's motion.

For U.S. Patent No. 12,031,784

• The Term: "separately movable relative to the body portion" (from claim 1)
• Context and Importance: This term is the core of the asserted inventive concept, which aims to solve the problem of bolt carrier interference. The case may turn on whether the accused device's "lever arm" is "separately movable" as the patent defines it.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The summary of the invention states the upward extension is "separately movable...between an extended position and a deflected position" and later mentions the invention provides a "deflectable extension" that "deflects or folds" '784 Patent, col. 1:63-65 '784 Patent, col. 2:49-50 This language may support an interpretation that covers a single, resilient part that bends or flexes.
  • Evidence for a Narrower Interpretation: The primary embodiment described in detail and shown in the figures depicts the deflectable portion (22) as a distinct component that "pivots on, for example a transverse pivot pin 24 relative to the locking bar body 26" '784 Patent, col. 3:40-42 '784 Patent, Fig. 2 This may support a narrower construction requiring a multi-component, hinged assembly.

VI. Other Allegations

• Indirect Infringement: The complaint alleges Defendants induce infringement by "encouraging, advertising, promoting, and instructing others to use and/or how to use the Atrius Selector" Compl. ¶34 Compl. ¶48 Compl. ¶62 Compl. ¶76 It also alleges contributory infringement, claiming that components of the Atrius Selector "are not suitable for substantial noninfringing use as they are specially designed and adapted" to infringe the patents Compl. ¶36 Compl. ¶50 Compl. ¶64 Compl. ¶78
• Willful Infringement: Willfulness is alleged on the basis that Defendants "have known or should have known" their actions constituted infringement and continued their activities despite an "objectively high likelihood" of infringement Compl. ¶37 Compl. ¶51 Compl. ¶65 Compl. ¶79 The allegations appear to be based on both pre- and post-suit knowledge.

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

The resolution of this dispute may depend on the court's determination of several key issues:

• A primary issue will be one of claim construction: can the term "separately movable" in the '784 patent, which is illustrated in the specification as a distinct, hinged component, be construed to cover the allegedly single-piece, flexible "lever arm" of the accused Atrius Selector?

• A second issue concerns the mechanism of operation: does the accused device's function in its "forced reset" mode meet the specific limitation of "preventing" the disconnector from catching the hammer, as required by the '247 patent, or does it achieve a fast reset through a different mechanical process that falls outside the claim's scope?

• A third question will be one of infringement and equivalence: even if not literally infringing, does the accused Atrius Selector perform substantially the same function in substantially the same way to achieve the same result as the claimed inventions, particularly with respect to the "separately movable" portion of the '784 patent and the disconnector "prevention" function of the '247 patent?