Litigation

Untitled case

1:21-cv-00149

Patents at issue (1)

Summary

The provided data indicates a case was filed, but the current status and specific parties are not detailed in the available information.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

An intellectual property dispute over firearm accessories has escalated amidst a contentious national debate on gun control regulations. The case pits operating company Rare Breed Triggers, LLC and patent-holding entity ABC IP LLC against competitors Big Daddy Enterprises, Inc. and Wide Open Enterprises, LLC. The lawsuit was filed in the U.S. District Court for the Northern District of Florida, Gainesville Division. At the heart of the litigation is U.S. Patent No. 10,514,223, which covers a "firearm trigger mechanism." This technology, known as a "forced reset trigger" (FRT), uses the energy from the firearm's cycling bolt carrier to mechanically reset the trigger, which can significantly increase the rate of fire compared to a standard semi-automatic trigger.

The plaintiffs assert that the defendants' "Wide Open Trigger" (WOT) is a direct copy of Rare Breed's FRT-15 product and infringes on the '223 patent. The court granted a preliminary injunction in favor of the plaintiffs on December 30, 2021, finding that Rare Breed was likely to succeed on the merits and would suffer irreparable harm from the direct competition in what it described as a "hot, niche market." The judge noted that the defendant, Wide Open Enterprises, LLC, appeared to be formed solely to sell the accused product, raising concerns that a future monetary judgment might be uncollectible. The case is procedurally situated in the plaintiffs' home state of Florida, a common venue choice for patent holders.

This case is particularly notable because it unfolds against the backdrop of a major regulatory and legal battle with the federal government. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) issued a letter in March 2022, classifying some FRTs as illegal machine guns under federal law. This led to cease-and-desist letters, product seizures, and separate lawsuits between Rare Breed Triggers and the Department of Justice (DOJ) in other districts. While the patent case in Florida focuses on infringement between competitors, the ATF's actions threatened the entire market for these products. Ultimately, following a key Supreme Court decision related to firearm accessories and a subsequent lower court ruling in Texas, the DOJ and Rare Breed reached a settlement in May 2025, allowing the continued sale of FRTs with certain conditions. This broader legal conflict over the legality of the technology itself elevates the significance of the commercial patent dispute in Florida.

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

As a senior US patent litigation analyst, here are the key legal developments and the outcome for the patent infringement litigation involving U.S. Patent No. 10,514,223.

Case Caption: RARE BREED TRIGGERS, LLC and ABC IP, LLC, Plaintiffs, v. BIG DADDY ENTERPRISES, INC. d/b/a BIG DADDY UNLIMITED, INC., and WIDE OPEN ENTERPRISES, LLC d/b/a WIDE OPEN TRIGGERS, Defendants.
Case Number: 1:21-cv-00149
Court: U.S. District Court for the Northern District of Florida, Gainesville Division

Summary of Outcome

The initial patent infringement litigation concluded on October 19, 2022, when the court entered a Consent Judgment and Permanent Injunction against the defendants. This effectively ended the first phase of the dispute in favor of the plaintiffs, Rare Breed Triggers and ABC IP.

However, the case has since been reopened and is currently active with post-judgment contempt proceedings. In July 2025, Plaintiffs filed a motion to hold Defendants in contempt for allegedly violating the permanent injunction, initiating a new phase of legal battles focused on enforcement and compliance.

Chronological Litigation Developments

Filing & Initial Pleadings (2021)

  • 2021-09-15: Plaintiffs Rare Breed Triggers, LLC (exclusive licensee) and ABC IP LLC (patent owner) filed a complaint for patent infringement against Defendants Big Daddy Enterprises, Inc. and Wide Open Enterprises, LLC. The complaint alleged that Defendants' "WOT Hard Reset Trigger" infringed on U.S. Patent No. 10,514,223, which covers a "forced reset trigger" mechanism for firearms. The plaintiffs accused the defendants, a former distributor of their product, of creating a "knock-off version" of their patented FRT-15™ trigger.

Pre-Trial Motions & Preliminary Injunction (2021)

  • 2021-12-30: In a significant early victory for the plaintiffs, U.S. District Judge Robert L. Hinkle granted a preliminary injunction against the defendants (ECF No. 47). The court found that the plaintiffs were likely to succeed on the merits of their infringement claim. The order prohibited the defendants from manufacturing, marketing, selling, offering to sell, importing, or transferring their "Wide Open trigger" or any substantially similar device.
  • The court's order included a preliminary claim construction analysis, finding that the asserted patent claim "plainly reads on both Rare Breed's FRT-15 and on the defendants' accused product." The court also determined that the plaintiffs would suffer irreparable harm in a "hot, niche market" without an injunction.

Settlement and Final Disposition (2022)

  • 2022-10-19: The case was resolved when the court entered a Consent Judgment and Permanent Injunction against the defendants. This judgment stipulated to the patent's validity and infringement by the defendants and permanently enjoined them from further infringement. The entry of this consent judgment concluded the merits phase of the litigation.

Post-Judgment Contempt Proceedings (2025 - Present)

  • 2025-07-15: The case became active again when Plaintiffs filed a "Motion to Reopen Case, Motion for Order to Show Cause Why Defendants...Should Not Be Held in Civil Contempt for Violation of Permanent Injunction" (ECF No. 200-1). Plaintiffs alleged that the defendants were violating the October 2022 injunction, indicating a new dispute over compliance and enforcement had erupted.
  • 2025-12-09: Judge Hinkle issued an order denying a motion filed by the defendants to disqualify the plaintiffs' outside counsel. The motion stemmed from the contempt proceedings and alleged a violation of a prosecution bar in the protective order. The court found that there was no "clear violation" of the order and that disqualification was not warranted.

Current Posture (As of May 2026)

  • The case is currently active and in a post-judgment phase focused on the contempt of court proceedings initiated by the plaintiffs. Recent docket activity in early 2026 relates to discovery disputes within these ongoing enforcement actions.

Parallel PTAB Proceedings

  • No evidence was found of any Inter Partes Review (IPR) or other Patent Trial and Appeal Board (PTAB) proceedings having been filed against U.S. Patent No. 10,514,223. The litigation appears to have proceeded without a parallel validity challenge at the USPTO.

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Based on a comprehensive review of court filings and legal publications, the following attorneys represent the plaintiffs, Rare Breed Triggers, LLC and ABC IP, LLC, in their patent infringement action.

Plaintiff's Counsel

Glenn D. Bellamy

  • Role: Lead Counsel (inferred from court filings and media reports).
  • Firm: Wood Herron & Evans LLP, Cincinnati, OH.
  • Note: Bellamy has over 35 years of experience in intellectual property litigation, with a specific focus on patents related to firearms. He was recently named the 2025 "Lawyer of the Year" for Litigation - Intellectual Property in Cincinnati by Best Lawyers®.

Josiah Contarino

  • Role: Of Counsel.
  • Firm: Contarino Roth LLC, Newark, NJ.
  • Note: Contarino is a founding partner of his firm, focusing on commercial litigation, and his firm's website highlights experience with the firearms industry. He has been recognized as a "Rising Star" in Business Litigation by Super Lawyers.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Based on a review of court filings and legal publications, the following attorneys have appeared on behalf of the defendants, Big Daddy Enterprises, Inc. and Wide Open Enterprises, LLC, in this patent infringement case.

Counsel for Defendants

For Big Daddy Enterprises, Inc. and Wide Open Enterprises, LLC:

  • Name: Benjamin L. England

    • Role: Lead Counsel (assumed based on filings).
    • Firm: Jones Foster P.A.
    • Office Location: West Palm Beach, Florida.
    • Note: Mr. England's practice focuses on intellectual property and commercial litigation, representing clients in patent, trademark, and copyright disputes.
  • Name: Michael J. Hooi

    • Role: Counsel.
    • Firm: St. Petersburg, Florida.
    • Note: Mr. Hooi has experience in business and intellectual property litigation.
  • Name: W. John Eagan

    • Role: Counsel.
    • Firm: Eagan & Donohue.
    • Office Location: Orlando, Florida.
    • Note: Mr. Eagan's experience includes commercial and civil litigation.
  • Name: Nicholas P. Minton

    • Role: Counsel.
    • Firm: Minton, Burton, Bassett & Collins, P.C.
    • Office Location: Austin, Texas.
    • Note: Mr. Minton specializes in intellectual property litigation, with a focus on patent cases.
  • Name: Franklin D. Ubell

    • Role: Counsel.
    • Firm: Minton, Burton, Bassett & Collins, P.C.
    • Office Location: Austin, Texas.
    • Note: Mr. Ubell has a background in handling complex patent litigation matters.

It is important to note that the specific roles of each attorney are not always explicitly stated in publicly available documents and have been inferred based on their appearances in filings. The legal representation was identified from various court documents, including the defendants' answer to the complaint and motions filed in the case. Further details may be available through a direct review of the case docket on PACER.