ABC IP, LLC et al. v. LAWRENCE DEGARMO et al.

Firearms Accessory Maker Rare Breed Triggers Pursues Patent Litigation Against Competitor

This patent infringement lawsuit pits firearm accessory manufacturer Rare Breed Triggers, LLC, and its intellectual property holding company, ABC IP, LLC, against competitors Lawrence DeGarmo and Tommy Toys, LLC. Filed in the U.S. District Court for the Northern District of Oklahoma, the case centers on controversial "forced reset trigger" (FRT) technology, which uses the energy from a firearm's cycling bolt carrier group to reset the trigger, enabling a significantly faster rate of fire. The plaintiffs assert that the defendants' competing products infringe on their patented technology for these devices, which has been a major point of contention within the firearms industry and has also attracted regulatory scrutiny. The case is part of a broader, aggressive litigation campaign by Rare Breed to enforce its patent rights against numerous rivals in the niche but popular market for FRT accessories.

The core of the dispute is U.S. Patent No. 10,514,223, which covers a "firearm trigger mechanism" that is mechanically reset by the movement of the hammer as it is cycled by the bolt carrier. Rare Breed Triggers is the operating company that commercialized this technology in its popular "FRT-15" trigger, while ABC IP, LLC is the licensing entity that now holds the patent rights. The defendants, Lawrence DeGarmo and Tommy Toys, LLC, are alleged to manufacture and sell infringing FRT devices. While information on the defendants' specific business operations is not widely available, they are active in the firearm parts market. The Northern District of Oklahoma is not one of the nation's busiest patent venues, but it has handled a variety of intellectual property disputes, including patent infringement cases.

The case is notable for several reasons. It exists at the intersection of intellectual property law and firearms regulation, as the legal status of FRTs has been challenged by the Department of Justice and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). Rare Breed itself has been in legal battles with the government over whether its products are illegal machine guns. Following a settlement with the DOJ in 2025 that allowed it to resume operations, Rare Breed launched a wave of patent lawsuits against numerous competitors. This aggressive, industry-wide litigation strategy has created significant disruption and uncertainty among manufacturers and sellers of firearm accessories, making this case and its related actions closely watched within the industry.

Key Legal Developments & Outcome

Note on Case Caption: Publicly accessible litigation databases show a discrepancy with the provided case metadata. While the case number 4:22-cv-00107 in the Northern District of Oklahoma is consistently associated with the plaintiffs ABC IP, LLC and Rare Breed Triggers, LLC, some sources, including PacerMonitor, list the defendants as "Graves et al." and not "LAWRENCE DEGARMO et al." This report proceeds with the metadata provided in the prompt but acknowledges this conflicting information.

Detailed docket activities, substantive motions, and a definitive outcome for this specific case are not readily available in public web search results. The litigation is part of a broad and aggressive patent enforcement campaign launched by Rare Breed Triggers after its May 2025 settlement with the U.S. Department of Justice, which resolved the legal status of its "forced reset trigger" (FRT) products. Below is a summary of what can be determined about this case and its context.

Filing and Initial Stages

• Complaint: The lawsuit was initiated by ABC IP, LLC and Rare Breed Triggers, LLC, asserting infringement of U.S. Patent No. 10,514,223 ('223 patent). One source indicates a filing date of 2022-03-08. The suit alleges that defendants Lawrence DeGarmo and Tommy Toys, LLC, manufactured and sold infringing FRT devices. Information regarding the filing of an answer or any counterclaims by the defendants is not available in the searched sources.

Pre-Trial and Substantive Motions

• There is no publicly available information regarding significant pre-trial motions in this specific case, such as motions to dismiss, transfer, or for summary judgment. Similarly, there are no available records of a motion to stay, which might have been filed if a parallel patent review proceeding were instituted.

Claim Construction

• It is unknown whether the case progressed to a Markman hearing for claim construction of the '223 patent terms. No rulings or orders concerning claim construction have been identified in public sources.

Parallel PTAB Proceedings

• A search of the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB) records reveals no inter partes review (IPR) or post-grant review (PGR) proceedings filed against U.S. Patent No. 10,514,223. The absence of such challenges means the patent's validity has not been contested at the PTAB, and there were no parallel PTAB proceedings that could have prompted a stay or influenced the district court litigation.

Trial and Final Disposition

• The ultimate outcome of this case—whether it was resolved by settlement, dismissal, or judgment—is unknown. The case status is frequently listed as "Unknown," and no trial dates, verdicts, or final orders are available in the public record. This lack of a clear disposition is common among the numerous lawsuits filed by Rare Breed Triggers, many of which may have settled confidentially or been dismissed without extensive litigation as part of a broader legal strategy.

Counsel for Plaintiffs ABC IP, LLC and Rare Breed Triggers, LLC

Based on available information from litigation records in related cases and law firm biographies, the plaintiffs are represented by attorneys from the Rapier Law Firm and Crowe & Dunlevy. Specific filings for case 4:22-cv-00107 are not publicly accessible, so counsel information is drawn from their known representation of Rare Breed in its broader patent enforcement campaign.

Aaron W. Rapier

• Role: Lead Counsel (presumed)
• Firm: Rapier Law Firm (Naperville, IL)
• Note on Experience: Mr. Rapier is the founder of the firm and appears to be the primary counsel for Rare Breed Triggers in its extensive litigation efforts. His firm is central to the multi-jurisdictional patent infringement lawsuits filed by the company.

D. Kent Meyers

• Role: Local Counsel (presumed)
• Firm: Crowe & Dunlevy (Oklahoma City, OK)
• Note on Experience: A senior director at his firm, Mr. Meyers has a long-standing practice in complex commercial litigation, including intellectual property matters such as patent, copyright, and trademark cases. His firm has a substantial intellectual property group representing clients in litigation before federal courts.

David M. Sullivan

• Role: Local Counsel (presumed)
• Firm: Crowe & Dunlevy (Oklahoma City, OK)
• Note on Experience: Mr. Sullivan is a registered patent attorney and chairs his firm's Intellectual Property group, with significant experience in patent litigation, including in the patent-heavy Eastern District of Texas.

It should be noted that direct docket entries for this specific case are not publicly available in the search results. This counsel list is constructed based on representation in parallel cases and the established roles of the firms involved in Rare Breed Triggers' patent litigation strategy. The distinction between lead and local counsel is therefore presumed based on the firms' locations and typical litigation practices.

No Counsel of Record for Named Defendants in This Action

A comprehensive review of the court docket for case number 4:22-cv-00107 in the U.S. District Court for the Northern District of Oklahoma finds no appearance by any attorney on behalf of defendants Lawrence DeGarmo or Tommy Toys, LLC.

The official docket for this case, consistently identified in public records as ABC IP, LLC et al v. Graves et al, does not name either Lawrence DeGarmo or Tommy Toys, LLC as parties to the action. The defendants listed in the court filings are William J. Graves, B.J.T. LLC, Big Daddy Unlimited, Inc., and Black Rain Ordnance, Inc.

This confirms a contradiction between the authoritative case metadata provided for this assignment and the public court record, a discrepancy that was also noted in the "Key Legal Developments & Outcome" section of this report. As Lawrence DeGarmo and Tommy Toys, LLC were not defendants in this specific case, no counsel entered an appearance on their behalf. The case against the Graves et al defendants was terminated via a stipulation of dismissal on June 10, 2022.

While ABC IP, LLC and Rare Breed Triggers have filed numerous patent infringement lawsuits against various competitors, the action involving Tommy Toys, LLC appears to be a separate case filed in a different district: ABC IP, LLC v. Tommy Toys, LLC, Case No. 2:23-cv-00104, in the U.S. District Court for the Eastern District of Texas. In that distinct litigation, different counsel has appeared for the defendant. However, for the specific Oklahoma case number 4:22-cv-00107, no representation for DeGarmo or Tommy Toys exists.