Rare Breed Triggers Inc et al. v. AS Designs LLC et al.

Case Overview

In a lawsuit filed on April 13, 2026, firearm parts manufacturer Rare Breed Triggers, Inc. and its associated intellectual property holding company, ABC IP LLC, have accused AS Designs, LLC, and individuals Calvin Olson and Matthew Karlovic of patent infringement. The plaintiffs, both operating companies in the firearm accessories market, allege that the defendants' "Super Safety,” “ARCFIRE Trigger – AMBI KIT,” and similar products infringe on two of their patents related to "forced reset triggers" (FRTs). These devices are aftermarket components, primarily for AR-15 style firearms, that use the energy from the cycling bolt carrier to mechanically reset the trigger, enabling a faster rate of fire while still firing only one round per trigger pull. This case is part of a broader, aggressive litigation campaign by Rare Breed against numerous competitors in the FRT market, a strategy that emerged after the company successfully settled litigation with the U.S. government, which had sought to classify FRTs as illegal machine guns.

The lawsuit was filed in the U.S. District Court for the Eastern District of Texas and is assigned to Judge Amos L. Mazzant. This venue is historically known as a favorable forum for patent plaintiffs due to its experienced judiciary, fast trial schedules, and local rules that can make litigation predictably expensive for defendants. The district has recently regained its status as the nation's top venue for patent cases. The asserted patents 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 describes a locking device for a forced reset trigger that allows it to be adapted for different firearm platforms, while the '247 patent covers a three-position trigger mechanism allowing the user to select between safe, standard semi-automatic, and forced reset semi-automatic modes.

The case is notable for several reasons. It represents a significant "intra-industry" legal battle following a major Second Amendment victory where Rare Breed, with the backing of gun rights groups, successfully argued that FRTs are not machine guns under federal law. A key condition of Rare Breed's settlement with the Department of Justice was that the company would actively enforce its patent rights, leading to the current wave of litigation against competitors like AS Designs. This has created controversy within the firearms community, with some companies vowing to support those sued by Rare Breed, arguing the patent claims are overly broad. The outcome of this and related lawsuits could consolidate the market for forced reset triggers and clarify the scope of Rare Breed's intellectual property in this contentious and innovative sector of the firearms industry.

Patent Litigation Now Centralized in Texas as Part of Broader MDL

The patent infringement lawsuit filed by Rare Breed Triggers Inc. and ABC IP LLC against AS Designs LLC is in its early stages and has been consolidated into a multi-district litigation (MDL) proceeding in the Eastern District of Texas. Key developments to date center on the case's transfer and inclusion in the MDL, which encompasses a wide-ranging enforcement campaign by Rare Breed following a settlement with the U.S. Department of Justice.

Case Background and Consolidation (2025-2026)

2025-12-30: Initial Lawsuit Filing
The case against AS Designs was originally filed by Rare Breed and ABC IP in the U.S. District Court for the Middle District of North Carolina, docketed as Case No. 1:25-cv-01192. The complaint alleged that AS Designs' "Super Safety," "ARCFIRE Trigger – AMBI KIT," and similar products infringe U.S. Patents No. 12,031,784 and 12,038,247, which relate to "forced reset trigger" (FRT) technology. FRTs are aftermarket firearm components that increase a weapon's rate of fire.

2026-04-02: JPML Creates Multi-District Litigation (MDL)
The Judicial Panel on Multidistrict Litigation (JPML) issued a Transfer Order centralizing six similar patent infringement actions, along with 24 potential "tag-along" actions filed by Rare Breed across the country, into a single proceeding. The JPML found that the cases involved common questions of fact, particularly concerning the alleged infringement of Rare Breed's patent portfolio by various FRT devices. The newly formed MDL was named In re: Rare Breed Triggers Patent Litigation, MDL No. 3176, and assigned to Judge Amos L. Mazzant, III, in the Eastern District of Texas, a venue noted for its experience with complex patent litigation.

2026-04-13: Case Transferred to the Eastern District of Texas
Following the JPML's order, the case against AS Designs was formally transferred to the Eastern District of Texas and assigned the new case number 4:26-cv-00370. Filings from the North Carolina court, including initial motions and pleadings, were transferred, but under local court rules, any pending motions are considered moot and must be re-filed to be considered by the MDL court.

Key Legal and Factual Context

This litigation campaign is directly linked to a settlement agreement between Rare Breed Triggers and the Department of Justice (DOJ), announced in May 2025. The settlement resolved a government lawsuit that had classified FRTs as illegal "machineguns." A key condition of the settlement requires Rare Breed to actively enforce its patents to prevent infringing products from entering the market, a measure intended to enhance public safety.

This unique mandate provides the backdrop for Rare Breed's numerous lawsuits against competitors, including AS Designs and makers of other FRT devices like the "Partisan Disruptor."

Status of Proceedings (as of May 2026)

As of the current date, the Rare Breed Triggers v. AS Designs case, now part of the broader MDL, is in the initial pre-trial phase.

• Pleadings: While an answer and counterclaims were filed in the original North Carolina venue, the parties will likely be subject to a new scheduling order from Judge Mazzant governing pleadings in the consolidated MDL.
• Pre-Trial Motions: No substantive pre-trial motions to dismiss or stay appear to have been re-filed and ruled upon in the MDL court since the April transfer. The docket primarily reflects the administrative consolidation of the various tag-along cases.
• Claim Construction and Discovery: The case has not yet progressed to a Markman hearing for claim construction, nor have significant discovery milestones been reached. These activities will be managed centrally by Judge Mazzant for all cases in the MDL to ensure consistency and efficiency.
• 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) petitions filed against the asserted patents (12,031,784 and 12,038,247) at this time. Such proceedings, if initiated by defendants, could potentially lead to a stay of the district court litigation.

The litigation is ongoing, and the next steps will likely involve Judge Mazzant issuing a comprehensive scheduling order to govern discovery, claim construction, and motion practice for all the consolidated cases. The final outcome—whether through settlement, trial, or dispositive motions—remains distant.

As of May 4, 2026, the counsel of record for the plaintiffs, Rare Breed Triggers Inc. and ABC IP LLC, have been identified from the initial filings in the case. The legal team comprises attorneys from two separate law firms, indicating a strategy of combining specialized intellectual property litigation experience with local counsel.

Plaintiff Counsel of Record

• Daniel L. Farris (Lead Counsel)

  • Firm: Foley & Lardner LLP, Chicago, IL.
  • Note: Farris is a technology and intellectual property attorney with a background as a software engineer, often advising on technology transactions, data security, and IP litigation.

• Benjamin M. Stern (Lead Counsel)

  • Firm: The Stern Law Firm, PLLC, Location not specified in initial search results.
  • Note: Stern focuses on intellectual property matters, including patent litigation, and has experience representing clients in various district courts known for patent cases.

• Jacob M. Lantry (Of Counsel)

  • Firm: The Stern Law Firm, PLLC, Location not specified in initial search results.
  • Note: Lantry's practice often centers on civil litigation, including product liability defense, and he has trial experience in multiple states for corporate defendants.

This legal team's composition suggests that Foley & Lardner may be handling the core technology and patent arguments, while The Stern Law Firm provides additional focused patent litigation support. The selection of counsel with experience in technology and extensive trial practice points to the plaintiffs' preparation for a potentially complex and contentious legal battle.

As of today, May 4, 2026, no counsel has formally filed a notice of appearance on behalf of the defendants AS Designs LLC, Calvin Olson, or Matthew Karlovic in this case.

The case is in its earliest procedural stages. The complaint was filed on April 13, 2026, and summonses for the defendants were issued on April 17, 2026. The docket does not yet reflect that the defendants have been formally served with the lawsuit.

Under the Federal Rules of Civil Procedure, defendants must file an answer or other responsive pleading within 21 days of being served. Until service is completed and that time period elapses, or until an attorney voluntarily makes an appearance, the representation for the defendants will not be officially recorded on the court's docket. Given that less than a month has passed since the case was filed, it is not unusual that defense counsel has not yet appeared.