Rare Breed Triggers Inc et al. v. HK Parts Inc

Firearm Accessory Makers Clash Over Rapid-Fire Trigger Technology

In a patent infringement lawsuit filed in the District of Utah, firearm accessory manufacturer Rare Breed Triggers, Inc. and its patent-holding affiliate, ABC IP, LLC, have accused competitor HK Parts Inc. of infringing two patents related to "forced reset trigger" technology. The plaintiffs, both operating companies in the firearms industry, allege that HK Parts is selling an adapted forced reset trigger mechanism that violates their intellectual property rights. This case places a spotlight on the lucrative and controversial market for aftermarket firearm components that increase a semi-automatic rifle's rate of fire.

The technology at issue, known as a forced reset trigger (FRT), uses the firearm's own cycling action to mechanically push the trigger forward after each shot, enabling a much faster reset and a higher potential rate of fire. The lawsuit asserts U.S. Patent No. 12,031,784, titled "Adapted forced reset trigger," which covers a trigger locking device adaptable to different firearm platforms, and U.S. Patent No. 12,038,247, titled "Firearm trigger mechanism," which describes a trigger assembly with a selectable "forced reset semi-automatic" mode. The complaint was filed on February 4, 2026, in the U.S. District Court for the District of Utah and has been assigned to District Judge Howard C. Nielson, Jr. and Magistrate Judge Jared C. Bennett. The choice of a Utah venue is notable as the defendant, HK Parts Inc., is incorporated and based in Salt Lake City.

This litigation is significant due to the recent and contentious legal history surrounding FRTs. These devices were the subject of regulatory efforts by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which classified some FRT models as illegal machine guns. That classification was successfully challenged in court, culminating in a May 2025 settlement between the Department of Justice and plaintiff Rare Breed Triggers, which affirmed the legality of FRTs under federal law for rifles. The settlement also reportedly required Rare Breed to enforce its patents against copycat designs, a possible motivation for the current lawsuit against HK Parts. This case is one of several similar infringement suits filed by Rare Breed and ABC IP against other competitors, suggesting an ongoing campaign to enforce its patent portfolio in this contentious market segment.

Key Legal Developments in Rare Breed Triggers v. HK Parts

Since its filing on February 4, 2026, the patent infringement lawsuit brought by Rare Breed Triggers and ABC IP against HK Parts in the District of Utah has become part of a significant, industry-wide legal conflict over forced reset trigger (FRT) technology. The case against HK Parts is one of numerous similar lawsuits Rare Breed has filed against competitors, a strategy seemingly stemming from a May 2025 settlement with the Department of Justice that affirmed the legality of FRTs and reportedly required Rare Breed to enforce its patents.

As of May 2026, the case is in its early stages but has been impacted by broader procedural developments involving Rare Breed's extensive litigation campaign.

Chronology of Key Events:

• 2026-02-04: Complaint Filed
  Rare Breed Triggers, Inc. and ABC IP, LLC filed a patent infringement complaint against HK Parts Inc. in the U.S. District Court for the District of Utah, asserting U.S. Patent Nos. 12,031,784 and 12,038,247. The case was assigned to Judge Howard C. Nielson, Jr. and referred to Magistrate Judge Jared C. Bennett.

• 2026-03-12: Summons Executed
  The summons was successfully served on the defendant, HK Parts, Inc., officially commencing the defendant's obligation to respond to the lawsuit.

• 2026-04-02: Case Transferred to Multidistrict Litigation (MDL)
  In a significant procedural development, the U.S. Judicial Panel on Multidistrict Litigation (JPML) issued a transfer order consolidating this case and 29 other similar lawsuits filed by Rare Breed into a single MDL proceeding for coordinated pretrial management. The JPML determined that the cases involved common questions of fact related to the asserted patents and the accused FRT technology.

  • MDL Name: In re: Rare Breed Triggers Patent Litigation
  • MDL Number: 3176
  • Transferee Court: U.S. District Court for the Eastern District of Texas
  • Presiding Judge: Honorable Amos L. Mazzant, III.

• 2026-04-16: Motion to Stay Denied as Moot (Implied)
  Prior to the MDL transfer, on April 16, 2026, court records indicate that Rare Breed filed a memorandum in opposition to a motion to stay that HK Parts had presumably filed. While the details of the stay motion are not fully clear from available information, such motions are common in patent cases, often requesting a pause pending the outcome of a PTAB review of the asserted patents. The subsequent transfer of the case to the MDL in the Eastern District of Texas would likely render this motion moot, with future scheduling and stays to be determined by the MDL judge.

Current Posture & Next Steps:

The case is now proceeding under the centralized authority of Judge Mazzant in the Eastern District of Texas as part of MDL No. 3176. All initial pleadings, scheduling, discovery, and claim construction (Markman) proceedings for this and the other consolidated cases will be handled there. This consolidation aims to prevent inconsistent rulings and conserve resources for the parties and the courts.

To date, there have been no substantive rulings on the merits of the infringement claims, no claim construction order, and no trial. The litigation is expected to first address overarching issues common to all defendants, such as the validity of the Rare Breed patents and the construction of key patent terms.

Parallel Proceedings at the Patent Trial and Appeal Board (PTAB):

There is evidence suggesting that the validity of Rare Breed's patents is being challenged outside of district court. Atrius Development Group Corp., a defendant in a separate but related case, filed a petition for Inter Partes Review (IPR) against at least one of the asserted patents, U.S. Patent No. 12,038,247. In a May 13, 2025, filing, patent owner ABC IP requested a discretionary denial of the petition, arguing that it had settled expectations regarding its patent rights following its extensive litigation and subsequent settlement with the U.S. Government.

The outcome of this and any other PTAB challenges could significantly impact the entire MDL, as a finding of invalidity by the PTAB could terminate the litigation against all defendants, including HK Parts. The MDL judge will likely coordinate the district court schedule with the progress of any instituted IPR proceedings.

Based on a review of court filings and legal databases, the following counsel have appeared on behalf of the plaintiffs, Rare Breed Triggers, Inc. and ABC IP, LLC.

Plaintiff's Counsel of Record

Aaron R. Gott

• Role: Lead Counsel (inferred)
• Firm: Bona Law PC (San Diego, CA)
• Note on Experience: Mr. Gott has represented Rare Breed Triggers in its prior high-stakes litigation against the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), successfully challenging the ATF's classification of forced reset triggers.

Matthew D. Lott

• Role: Local Counsel
• Firm: Lott Law (South Jordan, UT)
• Note on Experience: As a practitioner based in Utah, Mr. Lott is serving as local counsel for the plaintiffs in the District of Utah, where the case was originally filed before its transfer to multidistrict litigation.

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Disclaimer: This analysis is based on information available as of May 3, 2026. The case has been transferred to a Multidistrict Litigation (MDL) proceeding in the Eastern District of Texas (In re: Rare Breed Triggers Patent Litigation, MDL No. 3176). While the attorneys listed above filed the initial complaint, the MDL court may appoint a formal leadership structure, such as a Plaintiffs' Steering Committee, which could alter or add to the lead counsel roles for the consolidated litigation.

Counsel for Defendant HK Parts Inc.

Based on docket information for the case prior to its transfer to multidistrict litigation, the following attorneys have appeared on behalf of the defendant, HK Parts Inc. It is not yet clear if they will remain lead counsel within the consolidated MDL proceedings or if a defense steering committee will be appointed.

Jed H. Hansen

• Role: Lead Counsel (inferred)
• Firm: Thorpe North & Western, LLP
• Office Location: Sandy, Utah
• Note on Experience: Mr. Hansen focuses on intellectual property litigation and has experience in federal courts, including handling patent, trademark, and copyright disputes.

Michael Chibib

• Role: Of Counsel (admitted Pro Hac Vice)
• Firm: Chibib & Associates, P.C.
• Office Location: Austin, Texas
• Note on Experience: Mr. Chibib is an experienced patent litigator who has represented clients in numerous technology-related patent disputes, particularly in Texas federal courts.

Conor M. Civins

• Role: Of Counsel (admitted Pro Hac Vice)
• Firm: Bracewell LLP
• Office Location: Austin, Texas
• Note on Experience: Mr. Civins has a background in complex commercial and intellectual property litigation, including representing clients in patent infringement cases across various industries.

An April 9, 2026 order by Magistrate Judge Jared C. Bennett granted the pro hac vice motions for Michael Chibib and Conor M. Civins to appear in the Utah district court for HK Parts Inc. These appearances and a motion to stay filed by Mr. Hansen on April 2, 2026, occurred shortly before the Judicial Panel on Multidistrict Litigation transferred the case to the Eastern District of Texas.