Litigation
ABC IP, LLC et al. v. Timothy Hoffman et al.
active1:25-cv-00389
- Filed
- 2025-12-22
Patents at issue (1)
Plaintiffs (2)
Defendants (2)
Summary
An active case where the court granted a preliminary injunction for the plaintiffs. An amended complaint filed in February 2026 added allegations of infringement of the '723 patent, for which the plaintiffs are seeking past damages.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Case Background: Firearms Tech, 3D Printing, and Aggressive Patent Assertion
This patent infringement lawsuit is part of a broader, aggressive litigation campaign by plaintiffs ABC IP, LLC, and its exclusive licensee, operating company Rare Breed Triggers, Inc., concerning "forced reset trigger" (FRT) technology. This technology uses the energy from a semi-automatic firearm's reciprocating bolt carrier to mechanically reset the trigger, enabling a faster rate of fire. The defendants are Timothy Hoffman and his company, Hoffman Tactical, LLC, a well-known figure in the 3D-printed firearm community who designs and distributes files for components, including an FRT device known as the "Super Safety". The core of the dispute is the plaintiffs' allegation that Hoffman's Super Safety designs infringe on their intellectual property. The case is notable for its intersection of patent law with 3D-printing and the "do-it-yourself" firearms community, and for its context following a high-profile regulatory battle between Rare Breed Triggers and the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
The asserted patent is U.S. Patent No. 7,398,723, titled "Trigger forward displacement system and method." This patent, which expired in September 2024, generally covers a method where the firearm's reciprocating mechanism actuates a cam that forces the trigger to reset. The plaintiffs are seeking only past damages for infringement of this patent, an allegation added in an amended complaint filed in February 2026. This litigation campaign is also linked to a May 2025 settlement between Rare Breed and the Department of Justice, which resolved a dispute over whether FRTs were illegal machineguns. That settlement, favorable to Rare Breed, reportedly included a condition that the company would actively enforce its patent portfolio against potential infringers, a stipulation which some observers have characterized as the government "deputizing" a private company to suppress FRT technology it could not regulate directly.
The case was filed in the U.S. District Court for the Eastern District of Tennessee, where defendant Timothy Hoffman resides. The case is assigned to District Judge Curtis L. Collier. On February 11, 2026, the court granted a preliminary injunction for the plaintiffs, a significant early victory restricting Hoffman's activities. An appeal of the preliminary injunction has since been docketed at the U.S. Court of Appeals for the Federal Circuit. This case is one of dozens of similar lawsuits filed by the plaintiffs against various competitors across the country. In a significant procedural development, on April 2, 2026, the Judicial Panel on Multidistrict Litigation (JPML) ordered this case and numerous related actions to be centralized for coordinated pretrial proceedings in the U.S. District Court for the Eastern District of Texas under Judge Amos L. Mazzant, III, as MDL No. 3176, styled In re: Rare Breed Triggers Patent Litigation. This centralization aims to streamline discovery and avoid inconsistent rulings across the many parallel cases.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Patent Litigation Flares Over Forced-Reset Triggers in Tennessee Federal Court
KNOXVILLE, TN – A contentious patent infringement lawsuit is unfolding in the Eastern District of Tennessee, pitting the owners of forced-reset trigger (FRT) patents against a 3D-printed firearm component designer. The case, ABC IP, LLC et al. v. Timothy Hoffman et al., has seen the court grant an early-stage injunction against the defendants, an unusual intervention by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and an immediate appeal, signaling a high-stakes battle over firearm technology and intellectual property rights.
Filing and Initial Pleadings (2025-12-22 to 2026-02-16)
The lawsuit commenced on December 22, 2025, when Plaintiffs ABC IP, LLC and its exclusive licensee Rare Breed Triggers, Inc. filed a complaint against Timothy Hoffman and his company, Hoffman Tactical, LLC. The suit, filed in the U.S. District Court for the Eastern District of Tennessee, initially accused the defendants of infringing on patents related to their popular FRT-15 trigger. The defendants are known for designing and distributing 3D-printable firearm components, including a device known as the "Super Safety," which the plaintiffs allege infringes their patents.
Following the initial complaint, the plaintiffs filed an Amended Complaint on February 16, 2026. This amended pleading notably added allegations of infringement of U.S. Patent No. 7,398,723. The '723 patent had expired in September 2024, meaning the plaintiffs are only seeking past damages for its alleged infringement. The amended complaint also asserts infringement of U.S. Patent Nos. 12,038,247 and 12,031,784.
While the docket shows extensive motion practice, specific details regarding the defendants' answer or any counterclaims for patent invalidity are not yet available in the public search results. However, community discussion surrounding the case suggests a key defense contention is that the asserted patents are invalid based on prior art, including Hoffman's own alleged prior invention and public release of the "Super Safety" design.
Preliminary Injunction Proceedings and ATF Intervention (2026-01-13 to 2026-02-11)
A significant battle in the early phase of the litigation centered on the plaintiffs' request for immediate injunctive relief.
- Temporary Restraining Order (TRO): On January 13, 2026, the court granted a 14-day TRO in favor of the plaintiffs. The order prohibited Hoffman Tactical from selling or marketing the accused infringing devices and mandated the removal of the "Super Safety" design files from online platforms. The TRO was later extended to February 10, 2026, to allow the court to fully consider the preliminary injunction motion.
- ATF Statement of Interest: In a highly unusual move for a private patent lawsuit, the ATF filed a "Statement of Interest" on January 26, 2026. The agency argued that the "public interest" factor weighed heavily in favor of granting an injunction against Hoffman to promote "public safety" by discouraging the unregulated manufacture of forced-reset triggers. The ATF's filing referenced a May 2025 settlement agreement with Rare Breed, which resolved prior government litigation over whether FRTs were illegal machine guns. As part of that settlement, Rare Breed agreed to actively enforce its patent portfolio against competitors, leading some to characterize the company as a "deputized" enforcer for the government.
- Preliminary Injunction Granted: After a multi-day hearing, District Judge Curtis L. Collier granted the plaintiffs' motion for a preliminary injunction on February 11, 2026. The court issued a memorandum opinion detailing its reasoning and required the plaintiffs to continue a $20,000 injunction bond. The injunction prevents Hoffman from continuing the alleged infringement while the case proceeds.
Current Posture: Appeal and Ongoing Litigation (2026-03-13 to Present)
The defendants are challenging the court's interlocutory order. A Notice of Appeal regarding the preliminary injunction was filed on March 13, 2026. This appeal will be heard by the U.S. Court of Appeals for the Federal Circuit, which has jurisdiction over patent cases.
The case remains active in the district court, where proceedings on the merits of the patent infringement claims, including the allegations related to the expired '723 patent, will continue. The litigation is part of a broader, aggressive patent enforcement campaign by Rare Breed against multiple alleged competitors in the FRT market. There are no publicly available documents indicating if the case has proceeded to claim construction (a Markman hearing), nor are there any results of parallel challenges to the patents' validity at the Patent Trial and Appeal Board (PTAB).
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Whitaker Chalk Swindle & Schwartz
- Glen D. Bellamy · lead counsel
- Mack Ed Swindle · of counsel
- Decker A. Cammack · of counsel
- Fish & Richardson
- Benjamin J. Christoff · of counsel
- Carl Edward Bruce · of counsel
- Matthew Colvin · of counsel
Plaintiffs ABC IP, LLC and Rare Breed Triggers, Inc. are represented by attorneys from Whitaker Chalk Swindle & Schwartz PLLC and Fish & Richardson P.C. The legal team is composed of seasoned patent litigators with extensive experience in federal courts across the country.
Whitaker Chalk Swindle & Schwartz PLLC
This Fort Worth-based firm serves as lead counsel for the plaintiffs.
Glen D. Bellamy - Role: Lead Counsel.
- Firm: Whitaker Chalk Swindle & Schwartz PLLC, Fort Worth, TX.
- Note: Bellamy is listed on multiple filings in both the original Tennessee docket and after the case's transfer to Texas, indicating his continuing lead role in the multidistrict litigation (MDL) (Case 4:26-cv-00378, E.D. Tex., Dkt. ECF Notice, Apr. 15, 2026).
Mack Ed Swindle - Role: Of Counsel.
- Firm: Whitaker Chalk Swindle & Schwartz PLLC, Fort Worth, TX.
- Note: With over 48 years of experience, Swindle handles a range of complex commercial and intellectual property litigation, including patent infringement cases. He has been consistently recognized as a "Texas Super Lawyer".
Decker A. Cammack - Role: Of Counsel.
- Firm: Whitaker Chalk Swindle & Schwartz PLLC, Fort Worth, TX.
- Note: Cammack's practice is focused on patent litigation, and he has experience with firearms technology cases. He submitted a key declaration in this case and was previously an attorney at Fish & Richardson and Baker Botts. (Decl. of Decker A. Cammack, Case 1:25-cv-00389, Dkt. 54-1).
Fish & Richardson P.C.
Initially appearing pro hac vice in the Tennessee court, attorneys from Fish & Richardson are also representing the plaintiffs, a role that appears to have continued in related MDL proceedings.
Benjamin J. Christoff - Role: Of Counsel (pro hac vice).
- Firm: Fish & Richardson P.C., Washington, D.C.
- Note: Christoff is an experienced patent litigator with a history of representing clients in U.S. district courts, the Federal Circuit, and the ITC across a wide array of technologies. A motion for his pro hac vice appearance was granted in a related action (Case 1:25-cv-01262, N.D. Ohio).
Carl Edward Bruce - Role: Of Counsel.
- Firm: Fish & Richardson P.C., Dallas, TX.
- Note: Bruce has appeared for the same plaintiffs in a related patent infringement case in the Eastern District of Texas. He has a track record of securing summary judgment wins in patent cases within the district (Case 2:26-cv-00056, E.D. Tex.). His formal appearance in the Hoffman case post-transfer has not been confirmed from available records.
Matthew Colvin - Role: Of Counsel.
- Firm: Fish & Richardson P.C., Dallas, TX.
- Note: Colvin also represents the plaintiffs in the related Mister Guns case in the Eastern District of Texas. His litigation experience covers technologies including firearms, and he has managed large litigation teams from diligence through trial (Case 2:26-cv-00056, E.D. Tex.). His formal appearance in the Hoffman case post-transfer has not been confirmed from available records.
As the case was recently transferred to the Eastern District of Texas to be managed as part of a multidistrict litigation (MDL No. 3176), additional notices of appearance, including for local counsel, may be filed.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Blanchard Horton
- Jonathan M. Blanchard · lead counsel
- Jacob G. Horton · lead counsel
Based on a review of the docket and other publicly available information, the following counsel have appeared on behalf of defendants Timothy Hoffman and Hoffman Tactical, LLC in this matter.
Hoffman & Hoffman Tactical, LLC Counsel
Jonathan M. Blanchard
- Role: Lead Counsel
- Firm: Blanchard Horton PLLC
- Office Location: Oak Ridge, Tennessee
- Note: Dr. Blanchard has over 15 years of experience in intellectual property law, focusing on patent portfolio management and enforcement actions, and has experience with litigation licensed to settle multi-million-dollar disputes between international corporations.
Jacob G. Horton
- Role: Lead Counsel
- Firm: Blanchard Horton PLLC
- Office Location: Oak Ridge, Tennessee
- Note: Mr. Horton's practice includes intellectual property litigation and enforcement, and he has represented clients in numerous federal lawsuits; his technical experience specifically includes patents related to firearms and firearm accessories.