ABC IP, LLC et al. v. BIG DADDY ENTERPRISES, INC.

This patent infringement suit involves a legal battle over "forced-reset triggers," a firearm technology that allows for a dramatically increased rate of fire from semi-automatic rifles. The plaintiffs are Rare Breed Triggers, LLC, an operating company that manufactures and sells its flagship "FRT-15" forced-reset trigger, and ABC IP, LLC, the holding company for the intellectual property. The defendant, Big Daddy Enterprises, Inc., is a firearms and accessories retailer that began selling a competing product called the "Wide Open Trigger" or "WOT". The plaintiffs allege that Big Daddy's WOT trigger infringes on their patent, U.S. Patent No. 10,514,223. The '223 patent, titled "Firearm trigger mechanism," describes a trigger assembly where the cycling of the firearm's bolt carrier forces the trigger to reset, enabling the shooter to fire again almost immediately without needing to release the trigger manually.

The case was filed in the U.S. District Court for the Northern District of Florida, Gainesville Division, and is before Judge Robert L. Hinkle. This venue is significant as both Rare Breed Triggers and Big Daddy Enterprises have or had principal places of business in Florida. The procedural history includes a critical early ruling where Judge Hinkle granted a preliminary injunction on December 30, 2021, ordering Big Daddy Enterprises to stop selling the accused WOT trigger. In the order, the court found that the plaintiffs were likely to succeed on the merits of their infringement claim and were suffering irreparable harm from the defendant's sales.

The litigation is notable not only as a direct competitor dispute but also for its intersection with intense regulatory controversy. The technology at the heart of the patent, forced-reset triggers, has been the subject of significant legal challenges from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which has argued that such devices are illegal machine guns under federal law. This has led to separate, high-stakes litigation between Rare Breed Triggers and the U.S. government. The patent case against Big Daddy Enterprises is a key front in Rare Breed's attempt to control the market for this controversial technology, which it created and which has since seen knock-offs emerge. The outcome of this patent dispute will have a substantial impact on the niche but hotly contested market for rate-of-fire-enhancing firearm accessories.

Legal Developments & Outcome

Following the initial filings, the patent infringement litigation between Rare Breed Triggers and Big Daddy Enterprises moved quickly, marked by significant court rulings and eventual resolution, all while operating under the shadow of parallel regulatory challenges to the underlying technology.

Filing and Preliminary Injunction (2021)

• 2021-09-15: ABC IP, LLC and Rare Breed Triggers, LLC filed a complaint for patent infringement in the U.S. District Court for the Northern District of Florida, alleging that Big Daddy Enterprises' "Wide Open Trigger" (WOT) infringed on U.S. Patent No. 10,514,223.
• 2021-12-30: In a crucial early victory for the plaintiffs, Judge Robert L. Hinkle granted a preliminary injunction. The court ordered Big Daddy Enterprises and its affiliates to cease manufacturing, marketing, and selling the WOT trigger or any "substantially similar device." Judge Hinkle's order stated that the plaintiffs had demonstrated a high likelihood of success on the merits and would suffer irreparable harm if the defendant's sales continued. The court noted that the WOT appeared to be "plainly copied from the FRT-15" and that a potential monetary judgment against the defendant might be uncollectible.

Consent Judgment and Permanent Injunction (2022)

The case did not proceed to a full trial on the merits. Instead, the parties resolved the dispute through a consent judgment.

• 2022-10-19: The court entered a Consent Judgment and Permanent Injunction. This order permanently barred Big Daddy Enterprises, Inc., along with related entities and individuals, from making, using, selling, or offering for sale the WOT trigger or any other device that infringes on the '223 patent. This development effectively ended the litigation in favor of the plaintiffs, ABC IP and Rare Breed Triggers, by securing a permanent halt to the sales of the infringing product.

Post-Injunction Contempt Proceedings

Despite the permanent injunction, further legal action was necessary.

• Post-2022: At an unspecified date after the October 2022 judgment, the plaintiffs filed a motion to reopen the case. They sought an order for Big Daddy Unlimited, Inc., and other associated parties to show cause why they should not be held in civil contempt for allegedly violating the permanent injunction. This indicates that the plaintiffs believed the defendants or related entities were continuing to engage in infringing activities despite the court's explicit prohibition. The docket suggests these related cases were reopened to address these allegations. The outcome of these specific contempt proceedings is not detailed in the available search results.

Parallel Regulatory and Legal Challenges

Throughout the patent litigation, Rare Breed Triggers was embroiled in a separate, existential fight with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which classified forced-reset triggers as illegal machine guns. This regulatory battle culminated in a settlement with the Department of Justice (DOJ).

• 2025-05-16: The DOJ announced a settlement with Rare Breed Triggers, resolving multiple legal disputes regarding the ATF's classification of FRTs. This agreement was influenced by the Supreme Court's June 2024 decision in Garland v. Cargill, which held that bump stocks could not be classified as machine guns. As part of the settlement, Rare Breed agreed to enforce its patents against infringing products to advance public safety, a condition that reinforces the company's legal strategy seen in the Big Daddy Enterprises case.

Parallel PTAB Proceedings

The validity of the technology's patent protection has also been challenged at the U.S. Patent and Trademark Office.

• IPR Filing: Atrius Development Corp. filed a petition for Inter Partes Review (IPR) to challenge the validity of a related Rare Breed patent, U.S. Patent No. 12,038,247. While this IPR does not target the '223 patent asserted in the Big Daddy case, it is part of a broader legal assault on Rare Breed's intellectual property portfolio for forced-reset triggers and could influence future litigation. There is no information in the search results indicating an IPR was filed against the '223 patent itself.

In summary, the patent litigation ABC IP v. Big Daddy Enterprises concluded with a permanent injunction and consent judgment in favor of the plaintiffs, effectively halting the sale of the infringing "Wide Open Trigger." However, subsequent contempt proceedings were initiated to enforce this injunction. The case was a key part of Rare Breed Triggers' broader strategy to control the forced-reset trigger market, a strategy that continues through enforcement actions and is now intertwined with the company's 2025 settlement with the Department of Justice.

Plaintiffs' Counsel of Record

The plaintiffs, ABC IP, LLC and Rare Breed Triggers, LLC, are represented by attorneys from two primary law firms: Wood Herron & Evans LLP and Dhillon Law Group Inc. These lawyers have been active in filing motions and representing the plaintiffs' interests throughout the litigation, including securing a key preliminary injunction.

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Wood Herron & Evans LLP

Based in Cincinnati, Ohio, this boutique intellectual property firm has a long history dating back to 1868 and focuses exclusively on IP law, including patent litigation and prosecution.

• Name: Glenn D. Bellamy

  • Role: Lead Counsel
  • Firm & Location: Wood Herron & Evans LLP, Cincinnati, OH.
  • Notable Experience: A partner with over three decades of experience, Bellamy leads the firm's litigation practice and has extensive experience in patent and trademark cases involving firearms technology. He has represented Rare Breed Triggers in multiple legal matters, including filing amicus briefs before the Supreme Court and defending the company in other high-stakes litigation.

• Name: Charles D. Pfister

  • Role: Of Counsel (presumed, based on early case filings)
  • Firm & Location: Formerly of Wood Herron & Evans LLP; currently an associate at Taft Stettinius & Hollister LLP in their Dayton, OH office.
  • Notable Experience: Pfister's practice focuses on intellectual property litigation, including patent, trademark, and copyright matters; he was an associate at Wood Herron & Evans when the case was initially filed.

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Dhillon Law Group Inc.

A national firm with offices in California, Florida, New York, and Virginia, Dhillon Law Group handles high-stakes business, constitutional, and intellectual property litigation.

• Name: Josiah Contarino
  • Role: Counsel
  • Firm & Location: Dhillon Law Group Inc., Newark, NJ.
  • Notable Experience: Contarino has represented Rare Breed Triggers in other significant federal cases, including litigation against the U.S. government, demonstrating a close working relationship with the company on its most critical legal challenges. His practice includes complex commercial and intellectual property disputes. He recently founded the firm Contarino Roth, which specializes in firearms industry and civil rights litigation.

Based on a review of court filings and legal directories, the following attorneys have appeared on behalf of the defendant, Big Daddy Enterprises, Inc., in this patent infringement litigation.

Defense Counsel

• Name: William H. "Bill" Brewster

  • Role: Lead Counsel
  • Firm: Kilpatrick Townsend & Stockton LLP (Atlanta, GA)
  • Note: A veteran IP litigator and co-chair of his firm's Trademark & Copyright team, he has deep experience in federal court litigation involving trademark, false advertising, and patent disputes across the country.

• Name: Michael E. Jaffe

  • Role: Counsel
  • Firm: Pillsbury Winthrop Shaw Pittman LLP (Washington, D.C.)
  • Note: A senior litigator with extensive experience in complex commercial and international arbitration, his practice includes intellectual property disputes.

• Name: Kelly G. Swartz

  • Role: Local Counsel
  • Firm: Widerman Malek, PL (Melbourne, FL)
  • Note: Ms. Swartz is a Florida Bar board-certified specialist in intellectual property law with a background in computer engineering and experience in patent and trademark matters.

• Name: Benjamin J. Suro

  • Role: Local Counsel
  • Firm: Suro Rodriguez, PLLC (Gainesville, FL)
  • Note: Mr. Suro's practice focuses on federal litigation and business law, providing local representation in the Northern District of Florida.