Rare Breed Triggers Inc et al. v. 80mills LLC et al.

In a case emblematic of a contentious battle within the firearms accessory market, operating company Rare Breed Triggers Inc. and its licensing arm, ABC IP LLC, have sued 80mills LLC and Pearson Gardner for patent infringement. The lawsuit, filed on April 14, 2026, accuses the defendants of infringing two patents related to "forced reset triggers" (FRTs), which are devices that use the firearm's cycling action to dramatically shorten the time it takes for the trigger to reset, enabling a faster rate of fire. The accused product is the "Super Safety Cam Kit – CPM10V/A2," an aftermarket accessory for AR-15-style firearms that provides a three-position selector for "safe," "standard semi-automatic," and "active reset" modes. Rare Breed Triggers manufactures and sells its own FRT products, while 80mills LLC appears to be a retailer of firearm components.

The two patents asserted are U.S. Patent No. 12,031,784, titled "Adapted forced reset trigger," and U.S. Patent No. 12,038,247, titled "Firearm trigger mechanism." The '784 patent generally covers a locking device within a forced reset trigger mechanism that interacts with the firearm's bolt carrier. The '247 patent describes a selectable trigger mechanism that allows the user to choose between a standard semi-automatic mode and a forced reset semi-automatic mode. The case is proceeding in the U.S. District Court for the Eastern District of Texas before Judge Amos L. Mazzant, a venue that has regained its status as the nation's busiest patent court, known for experienced judges and a history of being favored by patent plaintiffs. This particular lawsuit is one of many similar cases filed by Rare Breed that were consolidated into a multidistrict litigation (MDL) and transferred to Judge Mazzant's court, underscoring the widespread nature of the enforcement campaign.

The case is notable for its connection to a high-stakes legal battle between Rare Breed and the U.S. government. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) previously classified Rare Breed's flagship FRT-15 trigger as an illegal machinegun, leading to federal litigation. In a May 2025 settlement, the Department of Justice dropped its case but required Rare Breed, as a condition of the agreement, to actively enforce its patent portfolio against alleged infringers. This has resulted in an aggressive and widespread litigation campaign against numerous, often smaller, competitors in the firearms industry, sparking significant backlash and making this series of lawsuits a closely watched event in the market.

As of today's date, May 1, 2026, the patent infringement litigation Rare Breed Triggers Inc et al. v. 80mills LLC et al. is in its very early stages. The case was filed just over two weeks ago, and the docket reflects only the initial proceedings. There have been no substantive motions, claim construction, or parallel PTAB decisions to date.

Key Legal Developments (Chronological)

• 2026-04-14: Complaint Filed
  The lawsuit was initiated by Rare Breed Triggers Inc. and ABC IP LLC against 80mills LLC and its principal, Pearson Gardner. The complaint (Dkt. 1) alleges that the defendants' "Super Safety Cam Kit – CPM10V/A2" infringes upon U.S. Patent Nos. 12,031,784 and 12,038,247, which relate to forced reset trigger technology. The plaintiffs are seeking damages and a permanent injunction.

• 2026-04-15: Case Assignment
  The case was assigned to Judge Amos L. Mazzant in the Sherman Division of the Eastern District of Texas. This assignment is significant as Judge Mazzant is also presiding over the consolidated multidistrict litigation (MDL) docket where numerous similar lawsuits filed by Rare Breed have been centralized, suggesting this case will likely be managed in coordination with the others.

• 2026-04-20: Summons Issued
  Summons were issued for defendants 80mills LLC and Pearson Gardner (Dkt. 4), officially notifying them of the lawsuit and setting the deadline for them to file a response to the complaint. Under the Federal Rules of Civil Procedure, a defendant typically has 21 days to respond after being served.

Pending and Future Events

• Answer or Motion to Dismiss: The next significant event will be the defendants' response to the complaint. They may file an Answer, admitting or denying the allegations and potentially asserting affirmative defenses or counterclaims of non-infringement, invalidity of the patents, or unenforceability. Alternatively, they could file a motion to dismiss under Rule 12(b)(6), arguing that the plaintiffs have failed to state a plausible claim for relief.

• Multidistrict Litigation (MDL) Coordination: Given that this case is one of many similar lawsuits filed by Rare Breed, it is highly probable that it will be formally coordinated or consolidated with the existing MDL (No. 32-cv-2500, In re: Forced Reset Trigger Patent Litigation) also before Judge Mazzant. This would mean that pretrial proceedings, such as discovery and claim construction, would be handled globally for all related cases to ensure consistency and efficiency.

• Parallel PTAB Proceedings: To date, no Inter Partes Review (IPR) or Post-Grant Review (PGR) petitions challenging the validity of the '784 or '247 patents have been identified at the Patent Trial and Appeal Board (PTAB). However, it is a common defense strategy for accused infringers in patent litigation to file such petitions. If an IPR were to be filed and instituted by the PTAB, the defendants in this case (and others in the MDL) would likely move to stay the district court litigation pending the PTAB's final decision on the patents' validity.

The case remains in its infancy, with the defendants' initial response still pending. The strategic direction of the litigation will become clearer once 80mills LLC and Pearson Gardner file their answer and once any motions regarding the MDL or potential PTAB challenges are brought before the court.

Plaintiff's Counsel of Record

As of May 4, 2026, counsel for plaintiffs Rare Breed Triggers Inc. and ABC IP LLC has appeared on the docket. The legal team is comprised of attorneys from the law firm Buether Joe & Carpenter, LLC, a Dallas-based intellectual property and complex commercial litigation boutique known for handling high-stakes patent cases.

• Christopher M. Joe - Lead Counsel

  • Firm: Buether Joe & Carpenter, LLC (Dallas, TX)
  • Note: Joe is a founding partner of the firm and has extensive experience leading patent infringement cases in the Eastern District of Texas, representing both plaintiffs and defendants in complex technology disputes.

• Eric W. Buether - Of Counsel

  • Firm: Buether Joe & Carpenter, LLC (Dallas, TX)
  • Note: A veteran trial lawyer and founding partner of the firm, Buether has secured significant verdicts in patent cases and is frequently involved in the firm's major litigation efforts.

• Brian A. Carpenter - Of Counsel

  • Firm: Buether Joe & Carpenter, LLC (Dallas, TX)
  • Note: Also a founding partner, Carpenter's practice focuses on intellectual property litigation, and he has represented clients in numerous patent disputes before federal courts.

The appearance of these attorneys was formally entered on the case docket at the time of the initial complaint filing (Dkt. 1) on April 14, 2026. The firm Buether Joe & Carpenter, LLC is representing the plaintiffs across the broader multidistrict litigation (MDL) involving Rare Breed's forced reset trigger patents, indicating a coordinated legal strategy.

Defendant Representatives

As of May 4, 2026, counsel for defendants 80mills LLC and Pearson Gardner has been identified from court filings originating in the case prior to its transfer to the Eastern District of Texas. While a formal notice of appearance may not yet be on the Texas docket, the following attorney has represented the defendants in prior proceedings related to this matter.

• John M. Skeriotis - Lead Counsel
  • Firm: Emerson Thomson Bennett (Akron, OH)
  • Note: Skeriotis is a partner and the Litigation Practice Chair at his firm, focusing on patent, trademark, and copyright litigation, and has represented clients in federal courts nationwide.

Representation was noted in filings related to the multidistrict litigation (MDL) transfer and in a case management conference held in the Northern District of Ohio before the case was moved to Texas. Skeriotis is specifically listed as the attorney for a motion to transfer filed on behalf of a group of defendants including 80Mills LLC and Pearson Gardner. His firm's website highlights his experience in patent infringement cases and proceedings before the U.S. Patent and Trademark Office.