Rare Breed Triggers Inc v. REDACTED Industries LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ABC IP, LLC (Delaware); Rare Breed Triggers, Inc. (Texas); RBTM LLC (Wyoming)
  • Defendant: Redacted Industries, LLC (Wyoming)
  • Plaintiff's Counsel: Koch Law, P.C.
• Case Identification: 2:26-cv-00191, D. Wyo., 06/17/2026
• Venue Allegations: Venue is alleged to be proper in the District of Wyoming because the Defendant resides in the district and has a regular and established place of business there.
• Core Dispute: Plaintiffs allege that Defendant's "Super Safety" trigger modification kits infringe five patents related to forced reset trigger mechanisms and firearm safeties.
• Technical Context: The technology concerns firearm trigger mechanisms, specifically "forced reset triggers," which use the energy from a firearm's cycling action to mechanically reset the trigger, enabling a faster rate of semi-automatic fire compared to standard designs.
• Key Procedural History: The asserted patents are part of a larger portfolio, with several patents claiming priority to the same or related applications, suggesting a strategic and ongoing patent prosecution effort in this technology space.

Case Timeline

Date	Event
2020-01-01	Plaintiffs allege use of the "FRT" mark began "Since at least 2020"
2021-11-05	U.S. Patent No. 12,031,784 Priority Date
2022-09-08	U.S. Patent Nos. 12,038,247, 12,578,159, and 12,636,403 Priority Date
2023-07-19	Date of "Super Safety Guide" referenced in complaint
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
2026-06-17	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: The patent describes a desire among firearm users to increase the rate of semi-automatic fire, but notes that prior art devices for achieving this have various shortcomings. Some require modified bolt carriers, while others present different technical challenges. Compl. ¶¶20-22 '247 Patent, col. 1:19-61
• The Patented Solution: The invention is a "drop-in" trigger mechanism for AR-pattern firearms that provides three distinct, selectable modes: safe, standard semi-automatic, and "forced reset" semi-automatic. '247 Patent, abstract In the "forced reset" mode, a cam, pivoted by the rearward movement of the bolt carrier, forces the trigger member back to its set position, allowing the user to fire again immediately upon the action returning to battery without first having to manually release the trigger. '247 Patent, col. 9:1-24
• Technical Importance: This design provides a multi-mode fire control group that can be installed as a modular unit into standard firearms without requiring modification to other core components like the bolt carrier. '247 Patent, col. 2:21-29

Key Claims at a Glance

• The complaint asserts independent claim 15. Compl. ¶40
• Claim 15 recites 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 the disconnector catches the hammer and the user must manually release the trigger to reset and fire again.
  • The mechanism is also operable in a "forced reset semi-automatic mode," where the cam forces the trigger to the set position and a safety selector prevents the disconnector from catching the hammer, allowing the user to fire again without manually releasing the trigger.
• The complaint reserves the right to assert additional claims. Compl. ¶40

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

Issued July 9, 2024

The Invention Explained

• Problem Addressed: The patent background explains that prior art forced reset triggers designed for one firearm platform (e.g., an AR15) may not function in another (e.g., an AR10) due to differences in component geometry and spacing. Specifically, extending a trigger locking bar to be actuated by a higher-positioned AR10 bolt carrier would cause it to interfere with a lower-positioned part of that same bolt carrier as it cycles. '784 Patent, col. 1:21-44
• The Patented Solution: The patent discloses a trigger locking device with an "upwardly extending deflectable portion." '784 Patent, abstract This portion is "separately movable" from the main body of the locking member, allowing it to pivot or fold out of the way when struck by the forward portion of the bolt carrier during its rearward cycle, but remain rigid to be actuated by the rear portion of the bolt carrier as it moves forward into battery. '784 Patent, col. 2:1-10 '784 Patent, col. 3:24-43
• Technical Importance: This innovation allows a single forced reset trigger design to be compatible with multiple firearm platforms (like the AR15 and AR10) that have different internal geometries, overcoming a key limitation of prior art. '784 Patent, col. 1:45-49

Key Claims at a Glance

• The complaint asserts independent claim 1. Compl. ¶54
• Claim 1 recites a trigger member locking device for a forced reset trigger, comprising:
  • A locking member movable between a first (locking) and second (unlocked) position.
  • The locking member has a body portion and an "upwardly extending deflectable portion."
  • This deflectable portion is "separately movable relative to the body portion between an extended position and a deflected position."
• The complaint reserves the right to assert additional claims. Compl. ¶54

U.S. Patent No. 12,529,538 - "Safety Mechanism for Firearm"

Issued January 20, 2026

• Technology Synopsis: The patent describes a safety mechanism employing a cam selector, a lever, and a trigger. The selector has multiple recesses and modes. In a first mode, the trigger tail moves within a first recess (standard operation); in a second mode, the trigger tail engages a second recess and is moved down by a cam portion (active reset); a third mode prevents the trigger from being pulled (safe). Compl. ¶25
• Asserted Claims: The complaint asserts independent claim 1. Compl. ¶68
• Accused Features: The "Super Safety" is accused of infringing by embodying a three-mode safety selector (safe, passive reset, active reset) that operates in the claimed manner. Compl. ¶¶68-70

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

Issued March 17, 2026

• Technology Synopsis: This patent, related to the '247 Patent, describes a device for accelerating a firearm's firing sequence. It can be selected to operate in either a standard semi-automatic mode or a "forced reset" mode, using a cam that is rotated by the cycling of the firearm's action to reset the trigger. Compl. ¶23
• Asserted Claims: The complaint asserts independent claim 1. Compl. ¶82
• Accused Features: The "Super Safety" is accused of infringing by providing selectable standard and forced reset semi-automatic modes. Compl. ¶¶82, 84

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

Issued May 26, 2026

• Technology Synopsis: The patent describes a device similar to the '247 and '159 patents, which can be selected to operate in two distinct modes: a standard disconnector-based semi-automatic mode and a forced reset semi-automatic mode. Compl. ¶26
• Asserted Claims: The complaint asserts independent claim 38. Compl. ¶96
• Accused Features: The "Super Safety" is accused of infringement by including a safety selector that allows movement between a standard semi-automatic position and a forced reset position. Compl. ¶¶96, 98

III. The Accused Instrumentality

• Product Identification: The accused products are the "Hoffman Tactical Super Safety Kit - Dual Mode," offered as a "partial kit" or a "complete kit," collectively referred to as the "Super Safety." Compl. ¶¶29-31
• Functionality and Market Context: The complaint alleges the Super Safety is a 3-position selector designed to replace a standard selector in an AR-15-pattern firearm. Compl. ¶29 Compl. p. 23 It is advertised as adding "Active and Passive reset modes" while retaining a safe position. Compl. p. 23 The complaint states that by moving the selector, a user can switch between a standard semi-automatic mode (termed "disconnector mode"), a forced reset semi-automatic mode, and a safe position. Compl. ¶32 The product is sold online via Defendant's website. Compl. ¶30 A photograph provided in the complaint shows the components of the kit, including various cams and levers. Compl. ¶31

IV. Analysis of Infringement Allegations

'247 Patent Infringement Allegations

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a hammer having a sear catch and a hook for engaging a disconnector...	The accused Super Safety is installed with a hammer that has a sear catch and a hook for engaging a disconnector.	¶42, p. 12	col. 7:45-47
a trigger member having a sear...	The Super Safety is installed with a trigger member that has a sear.	¶42, p. 14	col. 7:50-54
a disconnector having a hook for engaging said hammer...	The accused system includes a disconnector with a hook for engaging the hammer.	¶42, p. 15	col. 7:62-64
a cam having a cam lobe...	The Super Safety has a cam with a cam lobe and lever.	¶42, p. 16	col. 8:1-3
a safety selector adapted to be mounted in the fire control mechanism pocket to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions,	The Super Safety includes a selector that allows for selection of safe, standard ("passive"), and forced reset ("active") modes.	¶42, p. 37	col. 8:45-51
whereupon in said standard semi-automatic position... said disconnector hook catches said hammer hook... a user must manually release said trigger member to free said hammer...	In standard semi-automatic mode, the disconnector allegedly catches the hammer, and the user must manually release the trigger to reset and fire again.	¶42, pp. 18-19	col. 9:1-12
whereupon in a forced reset semi-automatic mode... said safety selector preventing said disconnector hook from catching said hammer hook... the user can pull said trigger member to fire the firearm without manually releasing said trigger member.	In forced reset mode, the selector allegedly prevents the disconnector from catching the hammer, and the user can fire again without manually releasing the trigger.	¶42, pp. 19-21	col. 9:13-24

'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: a locking member that is movable between a first position... and a second position...	The Super Safety is alleged to be part of a forced reset trigger mechanism and functions as an extended trigger member locking device that moves between a locked and unlocked position.	¶56, pp. 26-28	col. 2:54-58
the locking member having a body portion that is movably supported	The Super Safety has a body portion that is movably supported by the firearm's lower receiver.	¶56, p. 30	col. 2:61-62
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 deflectable lever arm with a dovetail connection designed to allow separate movement relative to the body portion.	¶56, pp. 30-32	col. 2:62-66

Identified Points of Contention

• Scope Questions: For the '247 patent, a central question may be whether the accused "disconnector mode" and "forced reset... with cam" modes Compl. ¶32 correspond to the specific operations of the "standard semi-automatic" and "forced reset semi-automatic" modes as defined in claim 15. For the '784 patent, the dispute may center on whether the accused device's "dovetail connection" Compl. p. 30 meets the "separately movable" limitation, which the patent describes in the context of a hinge or pivot. (784 Patent, col. 3:24-43).
• Technical Questions: A key evidentiary question for the '784 patent infringement allegation will be whether the accused lever arm is, in fact, "separately movable" from its body portion. The complaint shows a rendering of the lever arm in two different positions relative to its base, suggesting deflection. Compl. p. 31 The court will need to determine if this alleged movement is distinct from the movement of the body portion, as the claim requires.

V. Key Claim Terms for Construction

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

• The Term: "forced reset semi-automatic mode"
• Context and Importance: This term defines one of the core functionalities of the invention. Its construction is critical because infringement requires proving that the accused Super Safety operates in a mode that meets all the specific functional requirements laid out in the claim for this mode, including the cam forcing the trigger to reset and the selector preventing the disconnector from catching the hammer.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the invention provides "a 'three position' trigger mechanism having safe, standard semi-automatic, and forced reset semi-automatic positions." '247 Patent, abstract This general description could support an interpretation covering any system with these three general functions.
  • Evidence for a Narrower Interpretation: Claim 15 itself provides a detailed, multi-step functional definition, stating that in this mode, "rearward movement of the bolt carrier causes rearward pivoting of the hammer and pivoting of the cam... such that the cam lobe forces the trigger member to the set position, the safety selector preventing the disconnector hook from catching the hammer hook." '247 Patent, col. 9:13-20 This language may support a narrower construction requiring all of these specific interactions to occur.

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

• The Term: "separately movable relative to the body portion"
• Context and Importance: This term is the central inventive concept of claim 1, intended to solve the problem of geometric incompatibility between firearm platforms. Practitioners may focus on this term because the infringement case hinges on whether the accused device's lever arm, which uses a dovetail joint Compl. p. 30, is "separately movable" in the way the patent contemplates.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the feature more generally as a "deflectable extension... that deflects or folds to avoid interfering contact." '784 Patent, col. 1:49-53 This could support a reading on any mechanism that yields in one direction.
  • Evidence for a Narrower Interpretation: The detailed description and figures focus on embodiments with a "one-way hinge feature" '784 Patent, col. 2:1-2 or a pivot pin '784 Patent, FIG. 2 '784 Patent, col. 3:32-34, which could be used to argue for a narrower construction limited to pivoting or hinged movement, as opposed to other forms of deflection.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. For inducement, it alleges Defendant provides promotional materials and instructions on its website that inform and encourage customers to install and use the Super Safety in an infringing manner in an AR-15 firearm. Compl. ¶43 Compl. ¶57 Compl. ¶71 Compl. ¶85 Compl. ¶99 Compl. p. 23 For contributory infringement, it alleges the components of the Super Safety "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. ¶45 Compl. ¶59 Compl. ¶73 Compl. ¶87 Compl. ¶101
• Willful Infringement: The complaint alleges willful infringement for all asserted patents, based on the assertion that Defendant knew or should have known its actions constituted infringement of the presumptively valid patents and continued its activities despite an "objectively high likelihood" of infringement. Compl. ¶46 Compl. ¶60 Compl. ¶74 Compl. ¶88 Compl. ¶102

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

This case presents several focused technical and legal questions for the court's determination:

1. A central issue will be one of claim scope and construction: can the term "separately movable relative to the body portion" from the '784 patent, which the specification illustrates with a pivot hinge, be construed to read on the accused product's dovetail joint mechanism? The answer will likely determine infringement of that patent.
2. A second core issue is one of functional operation: does the accused "Super Safety" kit, when installed, perform the specific, multi-part sequence of operations required by the "standard semi-automatic mode" and "forced reset semi-automatic mode" as detailed in claims like claim 15 of the '247 patent? This will be a heavily fact-dependent inquiry relying on expert analysis of the accused product's mechanics.
3. Finally, a key question for damages and willfulness will be one of intent and knowledge. Did the Defendant, in marketing a kit with instructions for installation, possess the specific intent to encourage infringement, and did it act with knowledge of the patents despite an objectively high risk of infringement?