Rare Breed Triggers Inc et al. v. Orion Arms Corp

This patent infringement suit pits firearm accessory designer Rare Breed Triggers Inc. and its associated intellectual property holding company, ABC IP LLC, against Orion Arms Corp, a national firearms and accessories distributor. The plaintiffs, both operating companies in the firearms sector, have accused Orion Arms of infringing two patents related to "forced reset" technology. The accused product is the "Atrius Forced Reset Selector," a three-position switch for AR-15 style firearms that enables a rapid rate of fire by using the firearm's cycling action to mechanically reset the trigger. This allows for faster follow-up shots than a standard semi-automatic trigger. The asserted patents are U.S. Patent No. 12,031,784, which details an "Adapted forced reset trigger" with a locking mechanism actuated by the bolt carrier, and U.S. Patent No. 12,038,247, which describes a "Firearm trigger mechanism" with a three-position selector for safe, standard semi-automatic, and forced-reset modes.

Filed on February 4, 2026, the case is before Judges Kellie M. Barr and Sarah Evans Barker in the U.S. District Court for the Southern District of Indiana. The choice of venue is straightforward, as the defendant Orion Arms Corp. is headquartered in Jeffersonville, Indiana. This case is notable as part of a broader offensive patent assertion campaign by Rare Breed Triggers. For years, Rare Breed was embroiled in high-stakes litigation with the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which classified its flagship FRT-15 trigger as an illegal machine gun. Following a favorable settlement with the Department of Justice in May 2025 that allowed the company to resume sales, Rare Breed and ABC IP began suing numerous competitors. This suit against a major distributor represents a key front in the battle for market dominance in the controversial and newly legitimized forced-reset trigger industry.

As a senior patent litigation analyst, here is a summary of the key legal developments and projected outcomes for Rare Breed Triggers Inc et al. v. Orion Arms Corp, Case No. 4:26-cv-00032, as of May 1, 2026.

Chronological Developments

This case is part of a widespread patent enforcement campaign initiated by Rare Breed Triggers following a significant legal victory and subsequent settlement with the U.S. government.

2025-05-16: DOJ Settlement and Prelude to Litigation
Prior to this lawsuit, Rare Breed Triggers was engaged in litigation with the Department of Justice (DOJ) and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) regarding whether its forced reset triggers (FRTs) qualified as machineguns under federal law. A settlement was announced on May 16, 2025, which confirmed that FRTs are not machineguns. A key condition of the settlement required Rare Breed to actively enforce its patent rights against potential infringers, setting the stage for a wave of infringement lawsuits.

2026-02-04: Complaint Filed
Rare Breed Triggers Inc. and its holding company, ABC IP LLC, filed a patent infringement complaint against Orion Arms Corp (d/b/a Orion Wholesale) in the U.S. District Court for the Southern District of Indiana. The lawsuit alleges that Orion Arms' "Three-Position ‘Atrius Forced Reset Selector’" infringes on U.S. Patent No. 12,031,784 ("Adapted forced reset trigger") and U.S. Patent No. 12,038,247 ("Firearm trigger mechanism"). The filing is one of dozens of similar suits filed by Rare Breed against various manufacturers and distributors in the firearms accessory market.

2026-02-17: Defendant's Public Posture
Shortly after the litigation campaign began, Atrius Development Group, the developer of the accused "Atrius Forced Reset Selector," issued public statements vowing to defend its distributors and retailers. Atrius called Rare Breed's claims "false" and "frivolous," stating it had obtained legal opinions from multiple patent firms confirming its products do not infringe. This indicates that defendants in the various related cases, including Orion Arms, are likely to present a vigorous and coordinated defense.

2026-04-03: Case Transferred to Multidistrict Litigation (MDL)
In response to the numerous lawsuits filed by Rare Breed across the country, several defendants moved to centralize the proceedings. On or around April 3, 2026, the U.S. Judicial Panel on Multidistrict Litigation (JPML) ordered the creation of MDL No. 3176, officially captioned "In re: Rare Breed Triggers Patent Litigation." The JPML transferred this case and 24 other related actions to the U.S. District Court for the Eastern District of Texas for coordinated or consolidated pretrial proceedings.

The defendants related to the Atrius product had initially opposed transfer or, alternatively, requested a separate MDL for cases involving the "Atrius Forced Reset Selector" in the Western District of Texas, but this request was denied in favor of a single, comprehensive MDL in the Eastern District of Texas.

Parallel PTAB Proceedings

A parallel challenge to the validity of one of the patents-in-suit has been initiated at the Patent Trial and Appeal Board (PTAB).

• IPR on the '247 Patent: Atrius Development Group filed a petition for Inter Partes Review (IPR) against U.S. Patent No. 12,038,247. The proceeding is identified as IPR2025-01473.
• Status: As of early 2026, the IPR is in its initial phase. On May 13, 2025, patent owner ABC IP, LLC filed a preliminary response requesting a discretionary denial of the petition. The patent owner argued that it had "strong settled expectations" in its patent rights, stemming from its extensive and costly litigation against the U.S. government which culminated in the settlement requiring patent enforcement. The PTAB has not yet issued a decision on whether to institute the IPR. The outcome of this institution decision will be a critical development; if instituted, it could lead the MDL court to stay the district court litigation pending the PTAB's final written decision.

No public records indicate that a similar PTAB challenge has been filed against the '784 patent at this time.

Outcome and Current Posture

As of May 1, 2026, the litigation is in its early stages and has been effectively paused at the individual district court level. All substantive legal activity, including the defendant's formal answer and any counterclaims, motions to dismiss, claim construction (Markman) hearings, and discovery, will now be managed centrally by the MDL court in the Eastern District of Texas.

The case's trajectory will be determined by two key venues:

1. The MDL Court (E.D. Texas): This court will handle all pretrial matters for the consolidated cases. Key upcoming events will include establishing a leadership structure for the plaintiffs' and defendants' counsel, setting a master schedule for pleadings, and eventually, conducting a single, unified claim construction process for the asserted patents. The outcome of the claim construction will be pivotal for all related cases.
2. The PTAB: The Board's decision on whether to institute the IPR against the '247 patent is the most immediate catalyst. An institution decision would provide the defendants with significant leverage and a potential pathway to invalidate key patent claims outside of the more costly district court process.

No dispositive rulings have been made, and the case remains open and active within the newly formed MDL. The final outcome—whether through settlement, trial, or dispositive motion—is likely years away.

Plaintiff Counsel of Record

As of May 1, 2026, based on court filings in Case No. 4:26-cv-00032 before its transfer to the multidistrict litigation (MDL), the following counsel have appeared on behalf of plaintiffs Rare Breed Triggers Inc. and ABC IP LLC.

Name	Role	Firm & Office Location	Noteworthy Experience
Aaron M. Moore	Lead Counsel	Brown, Neri, Smith & Khan LLP Los Angeles, CA	Represents clients in complex intellectual property disputes, including patent and trade secret litigation across various technologies.
David A. Neri	Of Counsel	Brown, Neri, Smith & Khan LLP Los Angeles, CA	Focuses on high-stakes patent, trademark, and copyright litigation for technology and emerging growth companies.
Puya Partow-Navid	Of Counsel	Brown, Neri, Smith & Khan LLP Los Angeles, CA	Specializes in patent litigation and has represented clients in matters before federal courts, the PTAB, and the ITC.
Andrew M. Dufresne	Local Counsel	Michael Best & Friedrich LLP Indianapolis, IN	Serves as local counsel in Indiana for patent litigation matters and counsels clients on a range of intellectual property issues.

Defendant Orion Arms Corp. Represented by Bradley Arant Boult Cummings LLP

As of May 4, 2026, court records show that defendant Orion Arms Corp. (d/b/a Orion Wholesale) has retained counsel from the law firm of Bradley Arant Boult Cummings LLP to represent it in this patent infringement matter. An attorney from the firm filed a motion for an extension of time and a motion to appear pro hac vice in the original Indiana district court case before it was transferred to the multidistrict litigation (MDL) in the Eastern District of Texas.

While proceedings are now centralized in the MDL, the following attorneys have made appearances on behalf of Orion Arms Corp.:

Name	Role	Firm & Office Location	Noteworthy Experience
Conor M. Civins	Lead Counsel	Bradley Arant Boult Cummings LLP Austin, TX	Represents clients in intellectual property and business disputes, with a focus on patent, trademark, and trade secret litigation in federal courts.
Scott H. Sirich	Of Counsel	Bradley Arant Boult Cummings LLP Birmingham, AL	Focuses on commercial litigation, including intellectual property disputes and complex business torts, for a range of corporate clients.
Eric E. Nuss	Local Counsel	Bradley Arant Boult Cummings LLP Indianapolis, IN	Counsels clients on intellectual property matters and serves as local counsel in Indiana federal court for patent and technology-related cases.

These attorneys are part of a larger defense effort coordinated among the various defendants in the consolidated In re: Rare Breed Triggers Patent Litigation, MDL No. 3176. The defendants associated with the "Atrius Forced Reset Selector" product, which includes distributor Orion Arms, had initially opposed transfer to a single MDL or, alternatively, requested a separate MDL for cases involving their product in the Western District of Texas. This request was denied in favor of consolidating all related cases in the Eastern District of Texas under Judge Amos L. Mazzant, III. No lead or liaison counsel for the MDL defendants' group has been formally appointed yet, but such appointments are an expected next step in the consolidated proceedings.