Rare Breed Triggers Inc et al. v. Gaven L Poczekaj, Sr et al.

This patent infringement lawsuit is a key battleground in the highly contentious market for "forced reset triggers" (FRTs), a firearm technology that has faced intense regulatory scrutiny. The plaintiffs are Rare Breed Triggers Inc., an operating company known for its popular FRT-15 trigger, and its associated patent-holding entity, ABC IP LLC. They are suing Dairyland Defense Solutions LLC, a Wisconsin-based retailer of firearm parts, and its principal, Gaven L. Poczekaj, Sr. The accused products are firearm trigger mechanisms sold by Dairyland that allegedly infringe on the plaintiffs' patents. This case is part of a broader, aggressive litigation campaign by Rare Breed against numerous competitors, a strategy that has caused significant disruption in the firearm accessory industry.

The dispute centers on four patents related to trigger mechanisms that use the firearm's cycling action to reset the trigger, enabling a rapid rate of fire. The asserted patents are U.S. Patent Nos. 11,724,003, 12,274,807, and 12,036,336, which generally describe a trigger with a three-position selector for safe, standard semi-automatic, and forced-reset modes. Also at issue is U.S. Patent No. 10,514,223, which covers a trigger mechanism forced into its set position by the hammer's movement, a key feature of Rare Breed's flagship product. The case is being heard in the U.S. District Court for the Eastern District of Texas, a venue historically known for its experience with patent cases and plaintiff-friendly reputation. The case is assigned to Judge Amos L. Mazzant, who has a notably patent-heavy docket.

The case's notability stems from its context within the larger legal war over FRT technology. For years, Rare Breed Triggers fought the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which classified its FRT-15 as an illegal machine gun. Following favorable court rulings and a government settlement in 2025 that allowed the sale of FRTs to resume, Rare Breed has pivoted to aggressively enforcing its patent portfolio against competitors. This has led to accusations within the firearms community that the company is using "lawfare" to stifle competition and innovation in the very market it battled regulators to legitimize.

As of today, May 4, 2026, the patent infringement litigation involving Rare Breed Triggers is in its early stages, having been recently consolidated into a multi-district litigation (MDL) proceeding in the Eastern District of Texas. Key developments to date are primarily procedural, establishing the framework for the consolidated action.

Case Background and Consolidation

The case of Rare Breed Triggers Inc et al. v. Gaven L Poczekaj, Sr et al. is part of a broader legal campaign by Rare Breed Triggers and its intellectual property holding company, ABC IP LLC, to enforce its patents related to "forced reset triggers" (FRTs). These aftermarket firearm components are designed to increase a semi-automatic firearm's rate of fire.

This specific lawsuit was initially filed on June 13, 2025, in the U.S. District Court for the Eastern District of Wisconsin (Case No. 2:25-cv-00852). However, recognizing that numerous similar lawsuits had been filed by Rare Breed across various districts, the Judicial Panel on Multidistrict Litigation (JPML) took action.

On April 2, 2026, the JPML issued a transfer order to centralize the growing number of FRT patent cases for coordinated or consolidated pretrial proceedings. The panel designated the U.S. District Court for the Eastern District of Texas as the appropriate venue and assigned the litigation to Chief Judge Amos L. Mazzant, III. The newly formed MDL was initially named "In re: Super Safety Patent Litigation" but was quickly renamed "In re: Rare Breed Triggers Patent Litigation," MDL No. 3176, to more accurately reflect the scope of the dispute. The order noted that centralization would serve judicial efficiency by preventing duplicative discovery and inconsistent rulings on common issues like claim construction and patent validity.

Following the JPML's order, the case against Gaven L. Poczekaj, Sr., and Dairyland Defense Solutions LLC was officially transferred to the Eastern District of Texas on April 14, 2026, where it was assigned the current case number, 4:26-cv-00374.

Pleadings and Current Status

• Complaint: The original complaint, filed in Wisconsin, accuses the defendants of infringing U.S. Patent Nos. 11,724,003, 12,274,807, 12,036,336, and 10,514,223 by manufacturing and selling their own "firearm trigger mechanism."
• Answer: Publicly available docket information indicates that the defendants filed an answer to the complaint while the case was still in the Wisconsin district court. However, the specific contents of the answer, including whether it asserts counterclaims of non-infringement or invalidity, are not available from the search results.
• Current Posture: The case is currently open and pending as part of the consolidated MDL proceedings before Judge Mazzant. As the transfer and consolidation occurred very recently (in April 2026), the court has not yet issued a comprehensive scheduling order for the MDL. Such an order, which will govern deadlines for the entire litigation, is expected in the near future following an initial case management conference. All motions and deadlines from the original Wisconsin case are likely moot and will be superseded by the new MDL schedule.

Motions, Claim Construction, and Discovery

There have been no substantive motions, claim construction (Markman) hearings, or significant discovery milestones since the case was transferred and consolidated into the MDL. All such activities will be governed by the forthcoming MDL scheduling order.

Parallel PTAB Proceedings

A search of the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB) records indicates no Inter Partes Review (IPR) or Post-Grant Review (PGR) proceedings have been filed directly against the four specific patents asserted in this case (11,724,003; 12,274,807; 12,036,336; and 10,514,223).

However, related PTAB filings provide context. Documents from a separate proceeding, IPR2025-01473, show that other competitors have challenged different patents owned by ABC IP LLC that are part of the same broader family of FRT technology. Filings in that IPR reference U.S. Patent No. 11,724,003, indicating it was considered by the patent examiner during the prosecution of another related patent. While this does not affect the validity of the patents in the current case, it shows that the underlying technology is being actively scrutinized.

At present, there are no PTAB proceedings that would warrant a stay of this district court litigation.

Settlement or Final Disposition

The litigation is in its nascent stages within the MDL framework. No trial, settlement, or final judgment has occurred. Given the number of defendants involved in the consolidated litigation, the pretrial phase is expected to be lengthy and complex.

Based on docket information and further research, the following counsel from the law firm Fish & Richardson P.C. have appeared on behalf of plaintiffs Rare Breed Triggers Inc. and ABC IP LLC in this case. Given the firm's significant presence in the Eastern District of Texas and its role in numerous other related lawsuits for these plaintiffs, they are serving as national counsel.

Plaintiff's Counsel of Record

• Carl Edward Bruce - Lead Counsel

  • Firm: Fish & Richardson P.C., Dallas, TX office.
  • Note: A principal at the firm, Bruce has extensive experience in patent litigation, including matters in the Eastern District of Texas. His background is in chemical engineering, and he has represented clients in technologies ranging from oil and gas to software. He has been recognized as an "Energy and Environmental Trailblazer" by The National Law Journal for his work in building and enforcing patent portfolios.

• Matthew Alan Colvin - Lead Counsel

  • Firm: Fish & Richardson P.C., Dallas, TX office.
  • Note: Colvin is a principal whose practice focuses on complex intellectual property litigation, and his technical experience explicitly includes firearms technology. A former U.S. Air Force captain and engineering instructor, he has managed large litigation teams and argued numerous Markman hearings.

• Benjamin J. Christoff - Of Counsel

  • Firm: Fish & Richardson P.C. (His firm biography does not specify a primary office, but he is admitted to the Colorado and District of Columbia bars).
  • Note: Christoff is a principal with broad patent litigation experience across U.S. district courts, the International Trade Commission (ITC), and the Federal Circuit, where he previously clerked for The Honorable Jimmie V. Reyna. He is the co-author of Patent Law in a Nutshell with former Federal Circuit Chief Judge Randall R. Rader.

It is common in such multi-front litigation for a primary firm to act as national counsel, with attorneys from different offices contributing. Docket entries from related, now consolidated, cases show this team from Fish & Richardson representing Rare Breed and ABC IP in multiple jurisdictions.

As of May 4, 2026, counsel for the defendants Gaven L. Poczekaj, Sr. and Dairyland Defense Solutions LLC has not yet formally appeared on the docket in case number 4:26-cv-00374 in the U.S. District Court for the Eastern District of Texas.

The case was recently transferred to the Eastern District of Texas on April 14, 2026. Prior to the transfer, it was pending in the Eastern District of Wisconsin as case number 2:25-cv-00852, filed in June 2025.

A review of the available docket information for both the current Texas case and the prior Wisconsin case does not show a notice of appearance filed by an attorney or law firm on behalf of the defendants. It is common for defendants to secure counsel and file an appearance in the weeks following a complaint's filing or, in this instance, its transfer to a new district. Given that the transfer occurred less than a month ago, the defendants may still be in the process of retaining counsel to represent them in the new venue.

No news reports or other public records identify legal representation for the defendants at this stage. Therefore, information on the names, roles, and firms for defense counsel is not yet available.