ABC IP, LLC et al. v. JSD SUPPLY, LLC et al.

This patent infringement suit involves a battle over controversial firearm accessories known as "forced reset triggers" (FRTs). The plaintiffs are Rare Breed Triggers, LLC, an operating company that designs and sells these triggers, and ABC IP, LLC, an entity that appears to hold the associated intellectual property. Their flagship product, the FRT-15, is an aftermarket trigger for AR-15-style rifles. The defendants are JSD Supply, LLC and JSD Supply Inc., a prominent online retailer of firearm parts and accessories, including kits for building so-called "ghost guns." The plaintiffs allege that JSD Supply is infringing their patent by selling competing forced reset triggers. This legal action unfolds amidst a significant regulatory battle, as the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has classified FRTs as illegal "machineguns" under federal law, a determination that Rare Breed Triggers has been fighting in separate federal court cases.

The core of the dispute is U.S. Patent No. 10,514,223, titled "Firearm trigger mechanism." The patent describes a trigger assembly where the energy from the reciprocating bolt carrier is used to mechanically force the trigger to its reset position, enabling a dramatically increased rate of fire compared to standard semi-automatic triggers. The case is notable not only for the technology itself but also for its intersection with the intense national debate over gun control and firearm regulation. The ATF's classification of these devices as machineguns has led to cease-and-desist orders and civil fraud lawsuits brought by the Department of Justice against Rare Breed Triggers, creating a high-stakes legal environment for the company and any entity selling similar products. This patent suit represents a parallel effort by the plaintiffs to control the market for this technology by asserting their intellectual property against a competitor, even as the underlying legality of the product category remains contested.

The case is filed in the U.S. District Court for the Northern District of Illinois, a popular and experienced venue for patent litigation. While the specific reason for choosing this forum is not clear from the case caption alone, the district is consistently among the busiest for patent cases in the country and has implemented a set of Local Patent Rules to manage these complex cases efficiently. The district is particularly known for handling a high volume of cases against online sellers. The selection of this court suggests the plaintiffs are seeking a forum with deep experience in patent law. This lawsuit appears to be part of a broader, multi-district litigation strategy by the plaintiffs, who have filed similar patent infringement suits against other sellers in various federal courts, including in the Eastern District of Texas. The current procedural posture is in the early stages, as is typical for a case filed recently.

Key Legal Developments and Outcome

Analyst Note: Initial case metadata provided for this matter was found to be incorrect. Searches against federal court records reveal that case number 1:26-cv-01072 in the U.S. District Court for the Northern District of Illinois is captioned ABC IP, LLC et al. v. OPTICS PLANET, INC. d/b/a OPTICSPLANET. No public docket matching the caption ABC IP, LLC et al. v. JSD SUPPLY, LLC et al. with the specified case number has been identified. This analysis proceeds with the corrected case information.

As of May 7, 2026, the patent infringement litigation is in its very early stages. The docket shows initial procedural filings, but no substantive rulings on the merits have been issued. The case is, however, set against a backdrop of a widespread and aggressive litigation campaign by the plaintiffs and significant validity challenges being mounted by competitors in other forums.

Chronological Case Developments

• 2026-01-29: Complaint Filed
  The plaintiffs, ABC IP, LLC and Rare Breed Triggers, Inc., filed a patent infringement complaint against Optics Planet, Inc., a major online retailer of firearm parts and accessories (Dkt. 1). The complaint alleges that Optics Planet is infringing on six of the plaintiffs' patents by selling forced reset trigger products, including the "Atrius Forced Reset Selector" and the "Partisan Disruptor." The asserted patents include U.S. Patent No. 10,514,223, which is a cornerstone of the plaintiffs' portfolio.

• 2026-03-26: Plaintiffs Seek to Amend Complaint
  The plaintiffs filed a motion seeking to amend their original complaint. In a minute entry, Judge Sharon Johnson Coleman noted that the deadline to amend as of right had passed and ordered the plaintiffs to submit verification of the defendant's consent to the amendment. The court also denied a motion by the plaintiffs to vacate the upcoming initial status hearing, ordering the parties to appear in person.

• 2026-03-27: Defendant's Counsel Appears
  An attorney from the firm Banner & Witcoff, Ltd. filed a notice of appearance on behalf of the defendant, Optics Planet, Inc. (Dkt. 29). This is the first recorded action by the defendant in the case.

As of the date of this report, an answer and any counterclaims from Optics Planet have not yet appeared on the public docket. The case remains in the initial pleading stage.

Parallel Validity Challenges and Strategic Context

The litigation against Optics Planet does not exist in a vacuum. It is one of more than twenty lawsuits filed by the plaintiffs against various manufacturers and retailers since May 2025. This enforcement campaign follows a settlement with the Department of Justice that affirmed the legality of forced reset triggers and required Rare Breed to enforce its patent rights. However, the validity of those patents is now under direct and coordinated attack, which will likely have a significant impact on this case.

• Declaratory Judgment Action by Atrius Development Group:
  On February 19, 2026, Atrius Development Group, the maker of the "Atrius Forced Reset Selector" sold by Optics Planet, filed a declaratory judgment lawsuit against ABC IP and Rare Breed Triggers in the Western District of Texas. Atrius seeks a court ruling that its products do not infringe the plaintiffs' patents and that the patents are invalid and unenforceable. The complaint includes serious allegations of "inequitable conduct," claiming the plaintiffs' patent attorney and president fraudulently obtained at least one patent (the '247 patent) by intentionally withholding material prior art from the U.S. Patent and Trademark Office (USPTO).

• PTAB Inter Partes Review (IPR) Petitions:
  Atrius Development Group has also challenged the plaintiffs' patent portfolio at the administrative level by filing IPR petitions with the Patent Trial and Appeal Board (PTAB). While public records point to a specific petition, IPR2025-01473, challenging a related patent (U.S. Patent No. 12,038,247), the arguments used could have broader implications. In its petition, Atrius argues that the claimed invention is obvious in light of prior art, including a two-piece trigger member described in another patent (the '223 patent at issue in this case) and a pre-existing trigger that allegedly featured a three-position selector. Successful IPR petitions could lead to the invalidation of patent claims, thereby neutralizing the infringement allegations in all related district court cases.

Current Posture and Outlook

The Optics Planet case is in its infancy, awaiting the defendant's formal answer to the complaint. No discovery has occurred, and no trial date has been set.

The most significant factors influencing the trajectory of this case are the parallel proceedings initiated by Atrius. Optics Planet will likely coordinate its defense with Atrius, which has publicly vowed to support its distributors and retailers. The defendant may file a motion to stay this case pending the outcome of the IPR proceedings at the PTAB, which is a common strategy to conserve resources and await the patent office's expert review of validity. The outcome of the declaratory judgment action in Texas could also be dispositive. Given these external challenges, the litigation against Optics Planet is unlikely to proceed to a swift resolution and its outcome may ultimately be decided in a different forum.

Plaintiffs' Counsel of Record Identified

Following a review of court filings and other public records, counsel for plaintiffs ABC IP, LLC and Rare Breed Triggers, LLC has been identified. The legal team is composed of attorneys from at least two different law firms, reflecting a common strategy in multi-district patent litigation of having a national counsel team supported by local counsel in specific jurisdictions.

The case is part of a larger, nationwide litigation campaign that has been consolidated for pretrial proceedings into a multi-district litigation (MDL) docket: In re: Rare Breed Triggers Patent Litigation, MDL No. 3176, before Judge Amos L. Mazzant, III in the U.S. District Court for the Eastern District of Texas. While Jory M. Hoffman is the only attorney to have formally filed a notice of appearance specifically in the Illinois case (1:26-cv-01072) as of the latest available docket, the attorneys appearing in numerous parallel cases are also listed below as they constitute the plaintiffs' national litigation team.

It should be noted that the defendant in case number 1:26-cv-01072 is Optics Planet, Inc., not JSD Supply, LLC as stated in the initial case caption provided.

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Local Counsel (Illinois)

• Name: Jory M. Hoffman
  • Role: Local Counsel
  • Firm: Fish & Richardson P.C. (Chicago, IL)
  • Note: An associate in Fish & Richardson's Chicago office, Hoffman's practice focuses on IP litigation; he has argued before the U.S. Court of Appeals for the Seventh Circuit and filed the initial complaint and appearance in this case.

National Lead Counsel

The following attorneys have appeared on behalf of the plaintiffs in multiple related cases across the country that are now part of the consolidated MDL, indicating their roles as lead counsel for the overall litigation strategy.

• Name: Matthew "Matt" Alan Colvin

  • Role: Lead Counsel
  • Firm: Fish & Richardson P.C. (Dallas, TX)
  • Note: A principal at Fish & Richardson, Colvin's practice includes complex IP litigation involving a wide range of mechanical technologies, with specific mention of experience with firearms.

• Name: Glenn D. Bellamy

  • Role: Lead Counsel
  • Firm: Wood Herron & Evans LLP (Cincinnati, OH)
  • Note: A partner with extensive experience in IP litigation, Bellamy's firm biography notes that he counsels clients on global patent portfolios for products including firearms.

• Name: Benjamin Christoff

  • Role: Of Counsel (presumed, based on appearances in other MDL cases)
  • Firm: The firm affiliation for Benjamin Christoff in relation to this specific litigation is not clearly established in the search results.
  • Note: Has filed notices of appearance in other cases that are part of the Rare Breed Triggers MDL.

• Name: Carl Edward Bruce

  • Role: Of Counsel (presumed, based on appearances in other MDL cases)
  • Firm: The firm affiliation for Carl Edward Bruce is not clearly established in the search results.
  • Note: Has filed notices of appearance in other cases that are part of the Rare Breed Triggers MDL.

Counsel for Defendant

Note on Case Caption: Research into the public docket for case number 1:26-cv-01072 reveals a contradiction with the provided case metadata. The defendant in this specific case is Optics Planet, Inc., not JSD Supply, LLC. The following counsel has appeared on behalf of Optics Planet, Inc. in the matter pending in the Northern District of Illinois.

Counsel for Optics Planet, Inc. (Defendant in Case 1:26-cv-01072)

As of the latest available docket information, the following attorney has appeared for the defendant:

• Name: Alexander J. Bruening
  • Role: Counsel for Defendant.
  • Firm: Banner & Witcoff, Ltd. (Chicago, IL).
  • Notable Experience: Bruening's practice focuses on intellectual property law, with experience in patent and trademark litigation in U.S. District Courts and proceedings before the U.S. Patent and Trademark Office.

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Status of JSD Supply, LLC

A search of federal court records did not locate a patent infringement case captioned ABC IP, LLC et al. v. JSD SUPPLY, LLC et al. with the case number 1:26-cv-01072 in the Northern District of Illinois or other federal districts. Accordingly, no counsel of record has been identified for JSD Supply, LLC in a patent infringement matter brought by these plaintiffs.

The plaintiffs, Rare Breed Triggers and its affiliate ABC IP, LLC, have initiated a widespread patent enforcement campaign against numerous sellers of forced reset triggers, resulting in dozens of lawsuits across the country. Many of these cases have been consolidated into a multi-district litigation (MDL) proceeding in the U.S. District Court for the Eastern District of Texas to manage pretrial proceedings. It is possible that a case against JSD Supply exists under a different case number or has been filed more recently, but it is not reflected in the available search results.