RARE BREED TRIGGERS, INC. et al. v. B&T USA LLC et al.

Case Overview: Firearms Accessory Maker Launches Aggressive Patent Campaign

This patent infringement suit is part of a broader, aggressive litigation campaign launched in late 2025 and early 2026 by firearms accessory manufacturer Rare Breed Triggers, Inc. and its patent-holding affiliate, ABC IP, Inc. The plaintiffs, operating companies in the firearms sector, manufacture and sell the FRT-15, a "forced reset trigger" (FRT) for the popular AR-15 rifle platform. This drop-in accessory uses the energy from the bolt carrier group to mechanically reset the trigger, enabling a significantly faster rate of fire while, according to the company, remaining a legal semi-automatic device. The defendants are B&T USA LLC, the US-based distributor, and B&T AG, the Swiss parent company, both well-regarded manufacturers of high-end firearms and accessories. The specific accused products in this case have not been publicly identified in available documents, but are likely triggers for B&T's own firearm platforms that Rare Breed alleges incorporate its patented technology.

The core of the dispute is U.S. Patent No. 10,514,223, which covers a "trigger mechanism for a semi-automatic firearm" that includes the forced-reset functionality central to Rare Breed's products. The case, filed in the U.S. District Court for the District of Arizona, is one of dozens of similar suits Rare Breed has filed against competitors across the country. This wave of litigation followed a significant legal victory for Rare Breed against the U.S. government; in May 2025, the Department of Justice settled a lawsuit, agreeing that the FRT-15 trigger is not an illegal machine gun. As part of that settlement, Rare Breed agreed to enforce its patents against other makers of FRT devices.

The case is notable for its context within the highly competitive and politically charged firearms industry. After being sidelined by federal litigation, Rare Breed is now leveraging its patent portfolio to target numerous other companies that entered the FRT market. This has sparked significant industry backlash, with some competitors, like Atrius Development Group, publicly vowing to fight what they call "frivolous" and overly broad patent claims. Many of these related cases, initially filed in various districts, are now being consolidated into a multi-district litigation (MDL) proceeding, In re: Rare Breed Triggers Patent Litigation, to streamline pretrial proceedings. The outcome of this case and the broader MDL will likely have a significant impact on the market for advanced firearm triggers.

Legal Developments & Outcome

Based on available information, this specific case, RARE BREED TRIGGERS, INC. et al. v. B&T USA LLC et al. (2:25-cv-04938), appears to have been promptly consolidated into a broader multi-district litigation (MDL) proceeding. Direct public records for this specific case number show minimal unique activity before this transfer. The key legal developments are therefore those of the larger, centralized patent litigation campaign initiated by Rare Breed Triggers.

Chronological Developments

• 2025-12-23: Complaint Filed. Rare Breed Triggers, Inc. and its affiliate ABC IP, Inc. filed a patent infringement lawsuit against B&T USA LLC and B&T AG in the U.S. District Court for the District of Arizona, asserting U.S. Patent No. 10,514,223. This was one of numerous similar lawsuits filed against various competitors in the firearms industry.

• 2026-02-05: Plaintiffs Move to Consolidate. Rare Breed and ABC IP filed a "NOTICE of Motion to Transfer and Consolidate Related Cases". This motion argued that the numerous patent infringement cases filed across the country, including the one against B&T, involved common questions of fact and law regarding the '223 patent and should be centralized to preserve judicial resources and avoid inconsistent rulings. This filing marked the initial step toward creating the MDL.

Multi-District Litigation (MDL) Consolidation

Shortly after the initial filings in late 2025 and early 2026, Rare Breed's cases were consolidated into an MDL proceeding titled In re: Rare Breed Triggers Patent Litigation. This action effectively paused individual proceedings in district courts like Arizona. All significant pretrial matters, including discovery, claim construction (Markman hearings), and summary judgment motions for all consolidated cases, would be handled by the MDL court.

While specific rulings within the B&T case are not available post-transfer, developments in other related and highly publicized cases within the MDL provide insight into the broader legal strategy and potential outcomes:

• Key Test Case - The Partisan Triggers Injunction Hearing: In a closely watched related case against Peak Tactical (doing business as Partisan Triggers), Rare Breed moved for a temporary restraining order (TRO) and preliminary injunction to halt sales of the competing "Disruptor" trigger.
  • 2026-02-13: A federal judge in Wyoming denied Rare Breed's motion. This ruling was a significant early setback for Rare Breed's litigation campaign, allowing a key competitor to continue selling its product while the patent infringement lawsuit proceeds. The court found that Rare Breed had not met the high legal standard for the "extraordinary remedy" of an injunction.

Parallel PTAB Proceedings

As of early May 2026, there is no publicly available information indicating that B&T USA or B&T AG has filed an inter partes review (IPR) or other post-grant challenge against U.S. Patent No. 10,514,223 at the Patent Trial and Appeal Board (PTAB). However, given the widespread nature of the litigation, it is possible that other defendants in the MDL have filed or will file such challenges to the patent's validity.

Current Status and Outcome

The case against B&T USA is effectively stayed and administratively managed within the In re: Rare Breed Triggers Patent Litigation MDL. The ultimate outcome for B&T will be determined by the proceedings in that centralized litigation. Key events to watch for will be the MDL court's rulings on:

• Claim construction for the asserted patent claims.
• Motions for summary judgment on infringement and validity.
• The selection of bellwether cases for trial.

Given the early stage of the MDL, a final resolution through trial, settlement, or dispositive motion is likely some time away. The denial of the preliminary injunction in the Partisan Triggers case suggests that defendants have viable arguments against infringement or validity, and that Rare Breed may face a challenging path in enforcing its patent across the industry. It is also noteworthy that defendant B&T is not adverse to engaging in patent litigation itself, having recently filed a suit against SureFire, LLC in a separate matter concerning suppressor technology. This indicates a willingness to engage in complex intellectual property disputes.

Plaintiffs' Counsel Retain Elite National IP Firm for Aggressive Litigation Campaign

RARE BREED TRIGGERS, INC. and its intellectual property holding company, ABC IP, INC., have retained a high-powered legal team from the national intellectual property firm Fish & Richardson P.C. to lead its nationwide patent enforcement campaign, including in this case against B&T USA. The company also continues to use counsel from Wood Herron & Evans LLP, who represented them in earlier patent disputes. This combination of a premier, and likely more expensive, national firm alongside their prior counsel signals the plaintiffs' serious intent and significant financial investment in these cases.

The attorneys for the plaintiffs identified in this and related litigations are:

• Matthew A. Colvin | Lead Counsel

  • Firm: Fish & Richardson P.C., Dallas, TX
  • Experience: Colvin is a principal at Fish & Richardson and has extensive experience in patent litigation across various technologies. His appearance in multiple Rare Breed cases, including those against Partisan Triggers and AS Designs, LLC, indicates his central role in managing the overall litigation strategy.

• Carl E. Bruce | Of Counsel

  • Firm: Fish & Richardson P.C., Dallas, TX
  • Experience: As a principal in the Dallas office, Bruce's involvement alongside Colvin is noted in several of the Rare Breed enforcement actions.

• Benjamin C. "Ben" Christoff | Of Counsel

  • Firm: Fish & Richardson P.C., Washington, D.C.
  • Experience: A principal in the D.C. office of Fish & Richardson, Christoff's participation underscores the national scope of the legal team assembled for these patent cases.

• Glenn D. Bellamy | Of Counsel

  • Firm: Wood Herron & Evans LLP
  • Experience: Bellamy has represented Rare Breed Triggers in prior patent infringement litigation, including a successful 2022 preliminary injunction case against Big Daddy Enterprises and Wide Open Enterprises. His continued involvement suggests a long-standing relationship with the company.

• Charles D. Pfister | Of Counsel

  • Firm: Wood Herron & Evans LLP
  • Experience: Pfister worked alongside Glenn Bellamy in representing Rare Breed Triggers in its earlier successful patent litigation.

While a Justia docket report for case number 2:25-cv-04938 identifies an attorney named Matthew Colvin associated with a filing, the defendant in that specific docket entry is listed as Firearm Systems LLC, not B&T USA LLC. This discrepancy may be due to the mass-filing nature of the litigation and potential clerical errors or, more likely, indicates that the specific notice of appearance for the B&T case has not yet been made publicly available or has been sealed. However, given the consistent legal representation across the numerous other cases in this campaign, it is highly probable that the same team from Fish & Richardson and Wood Herron & Evans is representing the plaintiffs in this matter.

Notably, Kevin Maxwell, an owner of Rare Breed Triggers, has previously been identified as the company's general counsel in litigation against the U.S. government. However, there is no indication from available court records that he has entered an appearance as counsel in this patent infringement campaign.

As of May 7, 2026, counsel for defendants B&T USA LLC and B&T AG has not formally appeared in the U.S. District Court for the District of Arizona for this case. Shortly after its filing, the case was transferred to a consolidated multi-district litigation (MDL) proceeding, and the defense counsel leadership structure within the MDL has not yet been publicly established on the court's docket.

Case Transferred to Multi-District Litigation (MDL)

On April 2, 2026, the Judicial Panel on Multidistrict Litigation (JPML) issued a transfer order consolidating this case and numerous other similar patent infringement suits filed by Rare Breed Triggers into a single proceeding. The case, formerly 2:25-cv-04938 in the District of Arizona, is now part of MDL No. 3176, styled In re: Rare Breed Triggers Patent Litigation.

The consolidated cases are assigned to the Honorable Amos L. Mazzant, III, in the U.S. District Court for the Eastern District of Texas.

Status of Defense Counsel

Given the very recent nature of the MDL consolidation (just over a month ago), the court has not yet appointed lead counsel, liaison counsel, or a defendants' steering committee to manage the consolidated defense. Such appointments are typical in MDL proceedings but often take several weeks or months to formalize as the various defendant groups and their respective attorneys coordinate.

Searches of the dockets for the original Arizona case and the new MDL in the Eastern District of Texas do not show any notices of appearance specifically on behalf of B&T USA LLC or B&T AG. The MDL docket currently contains a placeholder for "Liaison Counsel for Defendants" but does not name any individuals.

Therefore, it is accurate to state that counsel of record for the defendants in this specific matter is not yet known. The attorneys who will ultimately represent B&T will likely appear on the MDL docket (Case No. 4:26-md-03176) in the Eastern District of Texas in the coming weeks.