RARE BREED TRIGGERS, INC. et al. v. PEAK TACTICAL LLC

Case Overview

The lawsuit between Rare Breed Triggers, Inc. and Peak Tactical LLC centers on so-called "forced reset triggers" (FRTs), a type of firearm accessory that significantly increases the potential rate of fire for semi-automatic rifles. The plaintiffs, Rare Breed Triggers and its intellectual property holding company, ABC IP, Inc., are operating companies that manufacture and sell the FRT-15, a popular forced reset trigger. They have initiated a broad legal campaign, filing numerous lawsuits against competitors in the firearm accessories market. The defendant, Peak Tactical LLC, operates a brand called Partisan Triggers which sells a competing forced reset trigger known as the "Disruptor." This case is part of a larger, aggressive intellectual property enforcement strategy by Rare Breed across the shooting sports industry.

The core of the dispute is the claim that Peak Tactical's products infringe on U.S. Patent No. 10,514,223. The '223 patent, titled "Firearm trigger mechanism," describes a trigger that is mechanically reset by the movement of the firearm's bolt carrier, which allows for rapid subsequent shots. Rare Breed alleges that Peak Tactical's forced reset triggers utilize this patented technology without a license. This litigation is notable not only for its focus on a controversial firearms accessory but also as a key front in Rare Breed's multi-jurisdictional effort to dominate the FRT market through patent enforcement. The company's legal actions follow a settlement with the U.S. Department of Justice, which had previously investigated whether FRTs should be classified as illegal machine guns.

The case is filed in the U.S. District Court for the District of Wyoming, a venue with a relatively small number of patent cases compared to other districts. Appeals from this court are directed to the U.S. Court of Appeals for the Tenth Circuit, except for patent claims which are appealed to the Federal Circuit. The selection of Wyoming as a venue could be a strategic choice by the plaintiffs, although the specific reasons are not publicly documented. One of the most significant developments in this case was the court's denial of Rare Breed's motion for a temporary restraining order and preliminary injunction, which would have halted sales of Peak Tactical's "Disruptor" trigger. This ruling was viewed as an early victory for the defendant, allowing them to continue selling their product while the litigation proceeds. The case highlights the intense competition and legal battles surrounding innovative, and sometimes controversial, firearm technologies.

Key Legal Developments & Outcome

This litigation is part of a broad and aggressive patent enforcement campaign by Rare Breed Triggers following a May 2025 settlement with the U.S. Department of Justice. That settlement, which resolved disputes over whether Rare Breed's forced reset triggers (FRTs) were illegal machine guns, included a condition that Rare Breed would actively enforce its patents. The case against Peak Tactical in Wyoming is one of dozens of suits filed against competitors in the firearm accessories market.

The case remains active and is in the pre-trial phase. The most significant development has been the early-stage denial of Rare Breed's request for an injunction to stop sales of the accused product, followed by a robust answer and counterclaim by Peak Tactical that challenges the validity of all asserted patents and alleges infringement of its own senior patent.

A chronological summary of key events follows:

• 2026-01-16: Complaint Filed. Rare Breed Triggers, Inc. and its IP holding company, ABC IP, Inc., filed a patent infringement suit against Peak Tactical LLC and its owner, Nicholas Norton. The complaint, lodged in the U.S. District Court for the District of Wyoming, alleged that Peak Tactical's "Disruptor" trigger willfully infringed four of Rare Breed's patents: U.S. Patent Nos. 10,514,223; 11,724,003; 12,036,336; and 12,274,807. The suit also included claims of false advertising under the Lanham Act.

• 2026-02-04: Preliminary Injunction Hearing. The court held an in-person hearing on Rare Breed's motion for a temporary restraining order (TRO) and preliminary injunction. Rare Breed argued that Peak Tactical's product was a "direct copy" and that its sales, projected to be over $4.8 million in 2026, were causing irreparable harm.

• 2026-02-13: Motion for TRO/Preliminary Injunction Denied. In a significant early victory for the defendant, the court denied Rare Breed's motion for a TRO and preliminary injunction. The ruling allows Peak Tactical to continue manufacturing and selling its Disruptor trigger while the case proceeds. The court found that Rare Breed had not sufficiently demonstrated irreparable harm, and it weighed the balance of hardships and public interest against granting the "extraordinary remedy" of an injunction.

• 2026-03-11: Plaintiffs' Motion for Expedited Discovery Denied. The court denied a subsequent motion from Rare Breed for expedited discovery. The court found no good cause for the request, viewing it as an attempt to relitigate the previously denied preliminary injunction.

• 2026-03-19: Motion to Centralize Litigation. Peak Tactical filed a motion with the Judicial Panel on Multidistrict Litigation (JPML) to centralize several related lawsuits initiated by Rare Breed against its dealers into the District of Wyoming. Peak Tactical argued that centralizing the cases, which involve the same accused product and asserted patents, would promote efficiency. The outcome of this motion is not yet clear from available documents.

• 2026-03-24: Answer and Counterclaims Filed. Peak Tactical filed a comprehensive 72-page answer and counterclaim, escalating the dispute significantly.

  • Non-Infringement: Peak Tactical denied all claims of infringement, arguing its "Disruptor" trigger is mechanically different and does not meet key limitations of Rare Breed's patents, such as the timing requirement of the bolt carrier being in a "substantially in-battery position."
  • Invalidity: The filing seeks declaratory judgment that all four of Rare Breed's asserted patents are invalid as obvious over prior art.
  • Counterclaim for Infringement: In a notable reversal, Peak Tactical accused Rare Breed's own FRT-15 triggers of infringing on U.S. Patent No. 9,146,067. This patent, which Peak Tactical owns, predates Rare Breed's patents and allegedly covers foundational assisted/forced reset trigger technology first commercialized in the Tac-Con 3MR trigger.
  • Inequitable Conduct Allegations: The counterclaim alleges that Rare Breed engaged in inequitable conduct before the U.S. Patent and Trademark Office by failing to disclose the '067 patent and other relevant prior art during the prosecution of its own patents. It further alleges that Rare Breed's counsel violated court-ordered prosecution bars in separate litigation.
  • Prior Purchase Attempts: The filing claims that Rare Breed attempted to purchase the '067 patent on two separate occasions (in 2021 and 2025) and was refused, suggesting Rare Breed was aware of the patent's relevance and its potential infringement exposure.

• 2026-05-01: Defendant Rebrands. Peak Tactical's brand, Partisan Triggers, officially rebranded as The Triggered Company. The legal proceedings continue under the new name.

Current Status and Outlook: The case is currently in the early stages of litigation, with the parties' initial pleadings and a key preliminary injunction ruling now on the docket. The denial of the injunction and the aggressive counterclaims from Peak Tactical have set the stage for a protracted legal battle. The case will now proceed through discovery, followed by claim construction (a Markman hearing), and potentially summary judgment motions and a trial. No trial date has been set, and there is no public record of any settlement discussions.

Parallel PTAB Proceedings: As of the current date, a search for inter partes review (IPR) proceedings at the Patent Trial and Appeal Board (PTAB) against U.S. Patent No. 10,514,223 or the other asserted patents does not yield any publicly available results involving these parties. The litigation appears to be confined to the district court at this time.

Based on an extensive review of dockets in parallel cases and media coverage of Rare Breed Triggers' nationwide patent enforcement campaign, the following attorneys and firms are representing the plaintiffs, Rare Breed Triggers, Inc. and ABC IP, Inc. It is highly probable that this same legal team is handling the Wyoming litigation, although a notice of appearance specific to case number 1:25-cv-00124 has not been publicly identified in the available search results.

Lead Counsel

Glenn D. Bellamy

• Role: Lead Counsel
• Firm: Wood Herron & Evans LLP (Cincinnati, OH)
• Note: Mr. Bellamy is an intellectual property attorney frequently named as lead counsel for Rare Breed Triggers in its numerous patent infringement lawsuits concerning forced reset triggers across multiple federal districts.

Carl E. Bruce

• Role: Lead Counsel
• Firm: Fish & Richardson P.C. (Dallas, TX)
• Note: Mr. Bruce, a principal at Fish & Richardson, has appeared as counsel for Rare Breed Triggers and ABC IP in several of their patent infringement cases.

Additional Counsel

Matthew A. Colvin

• Role: Of Counsel
• Firm: Fish & Richardson P.C. (Houston, TX)
• Note: A principal in Fish & Richardson's patent litigation group, Mr. Colvin has appeared on behalf of the plaintiffs in related patent cases.

Charles D. Pfister

• Role: Of Counsel
• Firm: Wood Herron & Evans LLP (Cincinnati, OH)
• Note: Mr. Pfister is an experienced patent litigator who has represented Rare Breed Triggers alongside Glenn Bellamy in earlier, related infringement actions.

Ben Christoff

• Role: Of Counsel
• Firm: Fish & Richardson P.C. (Minneapolis, MN)
• Note: Mr. Christoff is an associate at Fish & Richardson and has filed to appear pro hac vice for the plaintiffs in other forced reset trigger patent lawsuits.

B. Scott Eidson

• Role: Of Counsel
• Firm: Stinson LLP (St. Louis, MO)
• Note: Mr. Eidson has appeared for the plaintiffs in at least one of the related patent infringement cases filed in Missouri.

This team composition, combining attorneys from the intellectual property boutique Wood Herron & Evans LLP and the national powerhouse Fish & Richardson P.C., indicates the high-stakes nature of this multi-front litigation campaign for the plaintiffs. While local counsel for the District of Wyoming may also be of record, their identity is not available in the public search results at this time.

Counsel for Defendant Peak Tactical LLC

The defendant, Peak Tactical LLC, is represented by a team of attorneys from the national law firm Holland & Hart LLP. The team comprises partners and associates from the firm's Wyoming and Colorado offices, blending local trial experience with specialized expertise in intellectual property and patent litigation.

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Name: Timothy P. Getzoff
Role: Lead Counsel
Firm: Holland & Hart LLP (Boulder, CO)
Note: A partner in the firm's Boulder office, Getzoff has over 25 years of experience and has served as lead trial counsel in more than 150 high-stakes patent, trademark, and copyright litigation matters across the United States.

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Name: Andrew C. Orr
Role: Local Counsel
Firm: Holland & Hart LLP (Jackson, WY)
Note: Orr is the administrative partner of the firm's Jackson office and a trial lawyer with experience in complex commercial litigation in numerous states.

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Name: Jeffrey Scott Pope
Role: Local Counsel
Firm: Holland & Hart LLP (Cheyenne, WY)
Note: A partner in Cheyenne, Pope is an experienced litigator with a record of handling complex disputes and trials, often on issues of first impression in Wyoming.

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Name: Paul D. Swanson
Role: Of Counsel
Firm: Holland & Hart LLP (Denver, CO)
Note: Swanson is a partner who leads the firm's antitrust and competition practice and has significant experience in complex federal litigation and appeals.

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Name: Jeffrey "Randy" Roeser
Role: Of Counsel
Firm: Holland & Hart LLP (Boulder, CO)
Note: Roeser is an associate whose practice focuses on intellectual property litigation, with specific experience in patent litigation in federal courts, including the Eastern District of Texas.