ABC IP, LLC v. J. C. W. LLC

Case Overview: Firearms Tech Firm Asserts Patent on Forced-Reset Triggers

This patent infringement lawsuit, filed December 23, 2025, is part of a broader legal campaign by the plaintiffs, ABC IP, LLC and operating company Rare Breed Triggers, Inc., to enforce their intellectual property rights related to "forced-reset" firearm triggers. The defendants are Timothy Hoffman and his company, Hoffman Tactical, LLC, not J. C. W. LLC as initially stated in the case caption. The case centers on allegations that the defendants' "Super Safety" device—a trigger system design made available for users to create with 3D printers—infringes on the plaintiffs' patents. The technology in question allows a semi-automatic firearm's trigger to be mechanically reset by the energy of the reciprocating bolt carrier, which can enable a faster rate of fire. The case is notable for its context within the firearms industry, its connection to 3D-printing technology, and as a key part of a multi-front litigation effort by the plaintiffs that has been consolidated into multidistrict litigation (MDL).

The plaintiffs, ABC IP, LLC and Rare Breed Triggers, Inc., appear to be related entities, with ABC IP, LLC holding the patent portfolio and Rare Breed Triggers operating as the manufacturing and sales arm. They are asserting U.S. Patent No. 7,398,723, titled "Trigger forward displacement system and method," which describes a mechanism for increasing the cyclic rate of firing a semi-automatic firearm. The defendant, Hoffman Tactical, LLC, allegedly provides downloadable files and instructions that enable individuals to 3D-print and assemble the accused "Super Safety" trigger device. Plaintiffs have alleged both direct and indirect infringement, including inducement, and are seeking damages and injunctive relief. The complaint highlights a prior dispute and settlement with the defendants over a related patent, arguing this history supports a finding of willful infringement.

The case was filed in the U.S. District Court for the Eastern District of Tennessee. This court is part of the Sixth Circuit, but patent appeals are routed to the U.S. Court of Appeals for the Federal Circuit. Shortly after the case was filed, the court granted a preliminary injunction against the defendants on February 11, 2026, a significant early win for the plaintiffs. The case's significance is amplified by the fact that ABC IP, LLC and Rare Breed Triggers have filed numerous similar lawsuits against other companies in various districts. In April 2026, the Judicial Panel on Multidistrict Litigation (JPML) ordered this and other related cases transferred and consolidated for pretrial proceedings in the Eastern District of Texas, a popular venue for patent litigation, under the caption MDL 3176 In re: Rare Breed Triggers Patent Litigation. This consolidation underscores the industry-wide impact of the plaintiffs' enforcement actions.

Note on Case Caption and Parties

While the provided case caption is ABC IP, LLC v. J. C. W. LLC, docket information and litigation records indicate the defendant is Hoffman Tactical, LLC, and its principal, Timothy Hoffman. The analysis below follows the publicly available record for the case involving Hoffman, which bears the case number 1:25-cv-00389. The plaintiff is ABC IP, LLC, which is joined by Rare Breed Triggers, Inc., the exclusive licensee of the patents-in-suit.

Key Legal Developments

Here follows a chronological summary of the significant events in this patent litigation.

Filing and Initial Pleadings (2025-2026)

• 2025-12-22: Complaint Filed
  ABC IP, LLC, and Rare Breed Triggers, Inc. filed a patent infringement lawsuit against Timothy Hoffman and Hoffman Tactical, LLC in the U.S. District Court for the Eastern District of Tennessee. The suit initially asserted three patents related to "forced reset trigger" technology for semi-automatic firearms: U.S. Patent Nos. 7,398,723, 12,031,784, and 12,038,247. The plaintiffs alleged that the defendants' "Super Safety" device, distributed as a 3D-printable design, infringed their patents.

• 2026-02-10: Amended Complaint
  The plaintiffs filed an amended complaint against Hoffman Tactical and Timothy Hoffman. This filing occurred shortly after the court granted a preliminary injunction. The amended complaint maintained the core allegations of infringement and willful infringement, highlighting a prior 2022 settlement with the defendants over a related patent as evidence of willfulness. It was noted that U.S. Patent No. 7,398,723 had expired in September 2024, limiting claims on that patent to past damages.

Pre-Trial Motions and Injunction (2026)

• 2026-01-13: Preliminary Injunction Granted
  The court granted the plaintiffs' motion for a preliminary injunction, enjoining the defendants from further infringement of the asserted patents. While the specific reasoning for the injunction is not detailed in the search results, such orders typically require the plaintiff to show a likelihood of success on the merits, a risk of irreparable harm, that the balance of equities tips in their favor, and that an injunction is in the public interest.

• 2026-03-13: Appeal of Injunction
  The defendants, Hoffman and Hoffman Tactical, filed a notice of appeal to the U.S. Court of Appeals for the Federal Circuit, challenging the district court's order granting the preliminary injunction. A notice from the Sixth Circuit Court of Appeals confirmed that the appeal was properly directed to the Federal Circuit, which has exclusive jurisdiction over patent case appeals. An appeal was docketed at the Federal Circuit as case number 26-1775 on May 5, 2026.

• 2026-04-14: Case Transferred to Eastern District of Texas
  The case was transferred from the Eastern District of Tennessee to the Eastern District of Texas, where it was assigned the new case number 4:26-cv-00378. The reasons for the transfer are not specified in the available search results, but such transfers are often granted for reasons of convenience for parties and witnesses or if the original venue was improper. The case is one of several related actions involving ABC IP's patents that have been filed in or transferred to the Eastern District of Texas.

• Post-Transfer Stay Pending MDL Decision
  In a related case in the same district, ABC IP LLC v. Hawkphin Sales LLC (4:26-cv-00015), the court stayed deadlines pending a decision by the Judicial Panel on Multidistrict Litigation (JPML). This suggests that ABC IP and Rare Breed Triggers may be seeking to consolidate multiple lawsuits involving their forced-reset trigger patents into a single multidistrict litigation (MDL) proceeding for coordinated pre-trial management.

Parallel PTAB Proceedings (2025-2026)

• IPR Petition on the '247 Patent
  A third party, Atrius Development Group Corp., filed a petition for inter partes review (IPR) against U.S. Patent No. 12,038,247. The proceeding was docketed as IPR2025-01473 at the Patent Trial and Appeal Board (PTAB).

• 2026-02-18: PTAB Denies Institution of IPR
  The PTAB denied institution of the IPR petition. This was a significant victory for the patent owner, ABC IP, as it prevented a parallel validity challenge from proceeding at the patent office. The denial means the patent's validity remains presumed intact and the district court litigation can proceed without the cloud of a concurrent PTAB trial.

Outcome and Present Posture

As of May 2026, the litigation is active. Key developments include:

• Case Relocated and Potentially Consolidated: The case is now before the U.S. District Court for the Eastern District of Texas (4:26-cv-00378). Proceedings may be stayed pending a decision on forming an MDL to handle this and other related cases filed by the plaintiffs.
• Injunction Under Appeal: The preliminary injunction against the Hoffman defendants remains in effect but is being challenged at the Federal Circuit.
• No Final Disposition: There is no record of a final judgment, settlement, or dismissal of this specific case.

It is noteworthy that in May 2025, the U.S. Department of Justice announced a settlement with Rare Breed Triggers concerning the legality of forced-reset triggers, following a Supreme Court decision in Cargill v. Garland. That settlement resolved litigation between the government and Rare Breed but does not appear to directly resolve this private patent infringement action against Hoffman Tactical.

As of May 8, 2026, counsel of record for the plaintiff, ABC IP, LLC, in the matter of ABC IP, LLC v. J. C. W. LLC, Case No. 1:25-cv-00389, in the U.S. District Court for the Eastern District of Tennessee, cannot be definitively identified from available public records.

A search for the specific docket did not yield notices of appearance or a complaint listing the plaintiff's attorneys for this case. This may be because the case is newly filed and appearances have not yet been made, or because filings are currently under seal.

However, a review of other recent patent litigation filed by ABC IP, LLC across various U.S. district courts reveals a consistent pattern of legal representation. The following attorneys and firms have frequently appeared on behalf of ABC IP, LLC and are likely candidates to represent them in this matter:

Likely Counsel Based on Other ABC IP, LLC Patent Cases:

• Name: Benjamin "Ben" Christoff

  • Role: Likely Lead or Of Counsel
  • Firm: Fish & Richardson P.C. (Office location not specified in dockets, but the firm has offices nationwide)
  • Note: Mr. Christoff has appeared on behalf of ABC IP, LLC in multiple patent infringement cases, including matters in the Northern District of Ohio and the Eastern District of Washington.

• Name: Matt A. Colvin

  • Role: Likely Lead or Of Counsel
  • Firm: Fish & Richardson P.C.
  • Note: Mr. Colvin is listed as counsel for ABC IP, LLC in patent litigation filed in the Eastern District of Washington.

• Name: Carl Edward Bruce

  • Role: Likely Of Counsel (appeared pro hac vice in other cases)
  • Firm: Fish & Richardson P.C.
  • Note: Mr. Bruce has represented ABC IP, LLC in other patent matters, indicating his involvement in their litigation campaigns.

• Name: Glenn Dean Bellamy

  • Role: Likely Co-Counsel
  • Firm: Wood Herron & Evans LLP
  • Note: Mr. Bellamy has filed motions and appeared on behalf of ABC IP, LLC in conjunction with Fish & Richardson attorneys in other patent cases.

• Name: Susan C. Nelson

  • Role: Likely Local or Co-Counsel
  • Firm: Dunn & Black, P.S.
  • Note: Ms. Nelson is listed as counsel for ABC IP, LLC in a case in the Eastern District of Washington.

• Name: Kellie Nelson Fetter

  • Role: Likely Lead Counsel
  • Firm: Unknown
  • Note: Ms. Fetter filed a patent and trademark infringement complaint for ABC IP, LLC in the District of Wyoming.

Confirmation of the specific attorneys appearing in the Tennessee case will require a review of the official docket once notices of appearance are filed and made public.

Defendant's Counsel of Record

Following the consolidation of this case into multidistrict litigation (MDL), the attorneys representing defendants Timothy Hoffman and Hoffman Tactical, LLC have made appearances in the transferee court, the U.S. District Court for the Eastern District of Texas. The legal team is a combination of counsel from Florida and local counsel in Texas.

• Shane P. D'Souza (Lead Counsel)

  • Firm: D'Souza Law, P.A. (Miami, FL)
  • Note: Mr. D'Souza has represented Hoffman in prior disputes, including the settlement agreement that is a subject of the current litigation, and is also involved in representing other defendants in the consolidated MDL proceedings.

• Daniel L. Farris (Lead Counsel)

  • Firm: D'Souza Law, P.A. (Miami, FL)
  • Note: Mr. Farris is also representing multiple defendants alongside Mr. D'Souza in the broader MDL, indicating a central role in coordinating the defense strategy against Rare Breed Triggers' enforcement campaign.

• Theodore "Derick" Chandler IV (Local Counsel)

  • Firm: The Chandler Law Firm PLLC (Tyler, TX)
  • Note: Mr. Chandler frequently serves as local counsel in the Eastern District of Texas, a popular venue for patent litigation, and is listed on the docket for several defendants in the In re: Rare Breed Triggers Patent Litigation MDL.