Rare Breed Triggers Inc et al. v. Hoffman Tactical LLC et al.

In a significant patent infringement lawsuit within the firearms industry, operating company Rare Breed Triggers Inc. and its intellectual property arm, ABC IP LLC, are suing Hoffman Tactical LLC and its owner, Timothy Hoffman. The plaintiffs, who manufacture and sell high-performance "forced-reset triggers" (FRTs), allege that the defendants' "Super Safety" device infringes on four of their patents. Hoffman Tactical is a business that designs, sells, and provides 3D-printable plans for firearm components. The case is part of a large-scale patent enforcement effort by Rare Breed Triggers against numerous competitors, which began after the company settled a legal battle with the U.S. Department of Justice over the legality of FRT devices.

The core technology involves forced-reset triggers, which utilize the motion of a firearm's bolt carrier to mechanically reset the trigger, allowing for a much faster rate of fire compared to standard semi-automatic systems. The accused product, Hoffman Tactical's "Super Safety," is an "active reset trigger" system designed to replace the standard safety selector on an AR-15 platform to achieve this rapid-fire capability. The patents-in-suit cover key aspects of this technology:

• U.S. Patent No. 12,031,784: An adapted forced-reset trigger with a specialized locking device to ensure function across different firearm models.
• U.S. Patent No. 7,398,723: A system that uses a cam mechanism to forcibly displace the trigger forward, increasing the potential firing rate.
• U.S. Patent No. 12,529,538: A firearm trigger mechanism, though specific details from search results are limited.
• U.S. Patent No. 12,038,247: A trigger mechanism featuring a three-position selector for "safe," "standard semi-automatic," and "forced-reset" modes.

The case is filed in the U.S. District Court for the Eastern District of Texas and is assigned to Judge Amos L. Mazzant, a venue well-known for handling a high volume of patent litigation. The district is often favored by patent plaintiffs for its experienced judges and established local rules for patent cases. This lawsuit is particularly notable as it highlights the intersection of patent law and firearms regulation. Following a 2025 DOJ decision to no longer treat FRTs as illegal machine guns, Rare Breed Triggers reportedly agreed to enforce its patents against competitors making and selling similar devices. This legal campaign, including the case against Hoffman Tactical, represents a pivotal effort by Rare Breed to assert market control over a technology that has only recently emerged from significant regulatory uncertainty.

Legal Developments and Case Status

The patent infringement litigation between Rare Breed Triggers and Hoffman Tactical has been marked by aggressive legal maneuvering, significant preliminary rulings, and consolidation with a broader nationwide legal campaign by Rare Breed. The case is currently active in the Eastern District of Texas, proceeding toward pre-trial milestones under a preliminary injunction that restricts Hoffman Tactical's activities.

Filing, Injunctive Relief, and Transfer (2025-12-23 to 2026-04-14)

• Initial Lawsuit (2025-12-23): Rare Breed Triggers and ABC IP, LLC first filed suit against Timothy Hoffman and Hoffman Tactical in the U.S. District Court for the Eastern District of Tennessee (Case No. 1:25-cv-00389). The complaint alleged that Hoffman's 3D-printable "Super Safety" device infringed on at least three of their patents: U.S. Patent Nos. 12,038,247, 12,031,784, and 7,398,723.
• Temporary Restraining Order (2026-01-13): The Tennessee court quickly granted Rare Breed's request for a Temporary Restraining Order (TRO). The order prohibited Hoffman from selling, marketing, or distributing the Super Safety, and mandated the removal of the design files from online platforms like Odysee.
• DOJ Statement of Interest (2026-01-26): In a notable development, the U.S. Department of Justice (DOJ), through the ATF, filed a "Statement of Interest" in the case, supporting Rare Breed's motion for an injunction. The filing argued that halting the distribution of the Super Safety files would promote public safety, a move connected to a May 2025 settlement where the DOJ agreed to drop its own litigation against Rare Breed in exchange for the company's commitment to aggressively enforce its patents against competitors.
• Preliminary Injunction (2026-02-11): Following hearings in late January, District Judge Curtis L. Collier granted a preliminary injunction against Hoffman Tactical. The ruling, based on findings that Rare Breed was likely to succeed on the merits and would suffer irreparable harm, continued the prohibitions of the TRO for the duration of the case.
• Amended Complaint (Mid-February 2026): Shortly after securing the injunction, Rare Breed filed an amended complaint to add a newly issued patent, U.S. Patent No. 12,529,538, to the lawsuit.
• MDL Transfer (2026-04-02): The Judicial Panel on Multidistrict Litigation (JPML) issued a transfer order to consolidate the Hoffman Tactical case with five other similar lawsuits filed by Rare Breed against other sellers of forced-reset-style triggers. The JPML centralized these cases, officially named "In re: Rare Breed Triggers Patent Litigation" (MDL No. 3176), in the U.S. District Court for the Eastern District of Texas before Judge Amos L. Mazzant, a judge noted for his experience in complex patent litigation. The case was officially transferred and assigned its current case number, 4:26-cv-00378, on April 14, 2026.

Answer and Counterclaims

Following the transfer to Texas, the defendants are expected to file an answer to the amended complaint. Based on public statements and arguments made during the preliminary injunction phase, Hoffman's defense is expected to center on non-infringement and patent invalidity. A key contention is that Hoffman's "Super Safety" design was publicly released before the filing dates of Rare Breed's patents, potentially invalidating them based on prior art. There are also community allegations that Rare Breed acquired one of the patents fraudulently after it was filed by a third party who copied Hoffman's pre-existing design.

Parallel PTAB Proceedings

A significant factor in the litigation is the validity challenge against U.S. Patent No. 12,038,247, a key patent in the case.

• IPR Petition (2025-08-29): A third party, ATrius Development Group Corp., filed a petition for inter partes review (IPR) with the Patent Trial and Appeal Board (PTAB), challenging all claims of the '247 patent as obvious. The petition, docketed as IPR2025-01473, argued that the patent's claims were an obvious combination of prior art, including publicly available videos.
• Institution Denied (2026-02-18): The PTAB declined to institute the IPR. While the specific reasoning for the denial is not detailed in the available search results, this outcome was a significant victory for patent owner ABC IP, as it prevents this specific challenge from proceeding at the PTAB. This denial does not prevent other parties from challenging the patent's validity in district court or filing different IPR petitions, but it removes a major and efficient avenue for invalidating the '247 patent.

Current Posture and Next Steps (As of 2026-05-04)

The case is in its early stages before Judge Mazzant in the Eastern District of Texas. The preliminary injunction remains in effect, preventing Hoffman from distributing his Super Safety design. The immediate next steps will involve Hoffman filing an answer and any counterclaims to the amended complaint. Given the consolidation of multiple related cases into an MDL, the court will likely issue a scheduling order governing discovery, claim construction (Markman) proceedings, and other pre-trial matters for all defendants collectively. No trial date has been set, and the case remains open and highly contentious. Recent docket activity indicates that a notice of interlocutory appeal was transmitted to the U.S. Court of Appeals for the Federal Circuit on May 1, 2026, though the specific order being appealed is not immediately clear from the search results. This could potentially relate to the preliminary injunction order.

Plaintiffs' Counsel of Record

Based on a review of dockets in this and related multi-district litigation (MDL) cases, the plaintiffs Rare Breed Triggers, Inc. and ABC IP LLC have retained a consistent legal team from at least two law firms. While the specific docket for case 4:26-cv-00378 does not yet publicly list all counsel, the attorneys below have filed complaints, motions, and notices of appearance on behalf of the plaintiffs in numerous, nearly identical infringement suits that have been consolidated into MDL No. 3176 in the Eastern District of Texas.

Fish & Richardson P.C.

• Matthew A. Colvin | Lead Counsel

  • Firm & Location: Fish & Richardson P.C., Minneapolis, MN.
  • Noted Experience: Colvin is a principal at Fish & Richardson and has been listed as counsel in multiple related lawsuits filed by Rare Breed, often seeking pro hac vice admission to appear in various districts. His practice focuses on patent litigation across a range of technologies.

• Carl Edward Bruce | Lead Counsel

  • Firm & Location: Fish & Richardson P.C., Dallas, TX.
  • Noted Experience: As a principal in the Dallas office, Bruce frequently handles patent cases in the Eastern District of Texas and is listed on the dockets for several of Rare Breed's other infringement actions.

• Benjamin J. "Ben" Christoff | Of Counsel

  • Firm & Location: Fish & Richardson P.C., Minneapolis, MN.
  • Noted Experience: Christoff, a principal at the firm, has appeared alongside Colvin and Bruce in motions for pro hac vice admission in related Rare Breed cases, indicating a central role in the national litigation campaign.

Wood Herron & Evans LLP

• Glenn Dean Bellamy | Lead Counsel
  • Firm & Location: Wood Herron & Evans LLP, Cincinnati, OH.
  • Noted Experience: Bellamy appears to be a key attorney for the plaintiffs, as his name is on the filings for the amended complaint and other significant motions in related cases, suggesting a primary role in directing the litigation strategy. His firm biography notes extensive experience in IP litigation and trademark law.

Davis & Associates

• Whitney A. Davis | Of Counsel
  • Firm & Location: It is likely this is Whitney A. Davis of Davis & Associates in Austin, Texas, though this is not definitively confirmed by firm website searches.
  • Noted Experience: Davis is listed as the filing attorney on the original complaint in the related case against Hanes Tactical LLC, which was initially filed in the Western District of Texas before being transferred. This suggests a role in initiating the litigation campaign, potentially as local counsel in Texas.

Defense Counsel of Record

Based on a review of court filings and legal news coverage, the following counsel have appeared on behalf of defendants Hoffman Tactical LLC and Timothy Hoffman.

• Robert D. Schulte (Lead Counsel)

  • Firm: Schulte & Company LLC (Little Rock, AR)
  • Noteworthy Experience: Schulte has represented clients in numerous intellectual property and Second Amendment-related cases, including prior litigation involving firearm accessories and disputes with federal agencies like the ATF.

• Van A. Cates (Of Counsel)

  • Firm: Cates & Company (Little Rock, AR)
  • Noteworthy Experience: Cates has experience in complex commercial litigation and has previously collaborated with Robert D. Schulte on cases involving firearm-related technologies and intellectual property rights.

• Michael E. Jones (Local Counsel)

  • Firm: Potter Minton, P.C. (Tyler, TX)
  • Noteworthy Experience: Jones is a seasoned intellectual property litigator based in the Eastern District of Texas and frequently serves as local counsel in high-stakes patent cases due to his extensive experience before the district's judges.

• Stephen M. Gilbert (Of Counsel)

  • Firm: Stephen M. Gilbert P.A. (Angleton, TX)
  • Noteworthy Experience: Gilbert has a background in both patent law and Second Amendment litigation, making him uniquely suited for cases at the intersection of firearm technology and intellectual property disputes.

It is noted that Timothy Hoffman has also engaged in significant public fundraising efforts to support his legal defense team in this and related actions. Initial appearances and motions were filed in early 2026 following the case's transfer to the Eastern District of Texas.