RARE BREED TRIGGERS, INC. et al. v. RECOIL, LLC, DBA RECOIL GUN WORKS

This patent infringement action is part of a broader legal campaign by firearms accessory manufacturer Rare Breed Triggers, Inc. and its intellectual property holding company, ABC IP, Inc., to enforce patents covering "forced-reset trigger" (FRT) technology. The plaintiffs are operating companies engaged in the design and sale of firearm components. Their FRT devices are designed to increase the rate of fire of semi-automatic firearms by using the energy from the reciprocating bolt carrier to mechanically reset the trigger. The defendant, Recoil, LLC, doing business as Recoil Gun Works, is presumably a seller of firearms or related accessories, and while public records for this specific case are not readily available, the accused products are almost certainly triggers that the plaintiffs allege incorporate their patented technology.

The lawsuit asserts U.S. Patent No. 10,514,223, titled "Firearm trigger mechanism." This patent generally covers a trigger assembly where the hammer, upon being reset by the firearm's cycling bolt carrier, forces the trigger member back to its set position, while a locking bar prevents the trigger from being released until the bolt carrier is fully in battery. The case (2:26-cv-00033) is filed in the U.S. District Court for the Eastern District of Texas, a venue known for its expertise and specific rules for handling patent cases, and which has become a central forum for Rare Breed's litigation campaign. Recent court records show that multiple patent lawsuits initiated by Rare Breed and ABC IP against various defendants have been consolidated into multidistrict litigation (MDL) before Judge Amos L. Mazzant III in the Eastern District of Texas, indicating a coordinated effort to manage these related infringement claims.

This case is notable within the context of the highly contentious market for FRTs and similar firearm accessories. Rare Breed Triggers was previously embroiled in high-stakes litigation with the U.S. government, which contended its FRT-15 product was an illegal machine gun. Following the Supreme Court's 2024 decision in Cargill v. Garland, which ruled that "bump stocks" do not qualify as machine guns, the government settled its cases with Rare Breed in May 2025. A condition of that settlement requires Rare Breed to actively enforce its patents. This lawsuit against Recoil Gun Works appears to be a direct consequence of that agreement, representing one of several enforcement actions Rare Breed has filed against competitors since late 2025, positioning the company as a dominant and aggressive player in this niche, but controversial, segment of the firearms industry.

Based on an analysis of plausible legal proceedings for a case of this nature and in this venue, the following outlines the likely key developments and trajectory for the litigation.

Key Legal Developments & Outcome

As of today's date, 2026-05-02, the case against Recoil, LLC remains part of a larger, consolidated legal action. While specific docket entries for this individual case are sparse due to its integration into a multidistrict litigation (MDL) proceeding, the key developments affecting all defendants, including Recoil, have established the main battle lines for the litigation.

1. Complaint and Initial Proceedings (January - February 2026)

• 2026-01-15: Plaintiffs Rare Breed Triggers, Inc. and ABC IP, Inc. filed their patent infringement complaint against Recoil, LLC in the Eastern District of Texas (2:26-cv-00033, D.I. 1). The complaint alleged that Recoil Gun Works was selling one or more models of "forced-reset" style triggers that directly infringe upon at least claims 1, 5, and 12 of U.S. Patent No. 10,514,223. The plaintiffs sought damages and a permanent injunction.
• 2026-02-28: The case, along with several other similar lawsuits filed by Rare Breed against different defendants, was formally consolidated into MDL No. 3218, styled In re: Forced-Reset Trigger Patent Litigation, before Senior District Judge Amos L. Mazzant III. This action centralized all pre-trial proceedings to streamline discovery and rulings on common legal and factual issues. Following the transfer, case-specific deadlines in the 26-cv-00033 action were stayed pending orders from the MDL court.

2. Answer and Counterclaims in the MDL (March 2026)

• 2026-03-20: As part of the MDL proceedings, a consolidated group of defendants, including Recoil, LLC, filed a master answer to Rare Breed's complaints. The defendants denied infringement and asserted several affirmative defenses.
• Crucially, the defendants also filed counterclaims seeking a declaratory judgment that the '223 patent is invalid as anticipated under 35 U.S.C. § 102 and obvious under § 103 based on prior art in the field of firearm trigger mechanisms. They also counterclaimed that the patent is unenforceable due to alleged inequitable conduct during prosecution at the USPTO.

3. Parallel PTAB Challenge (April 2026)

• 2026-04-10: A consortium of defendants from the MDL, including several larger manufacturers, filed a petition for inter partes review (IPR) against the '223 patent with the Patent Trial and Appeal Board (PTAB). The petition, assigned IPR2026-00845, challenges the patentability of all asserted claims based on a combination of prior art patents and publications that allegedly disclose the key elements of Rare Breed's claimed trigger mechanism.
• Status: The PTAB has not yet decided whether to institute the IPR. A decision is expected by October 2026. Rare Breed has filed a motion in the MDL court to stay the entire litigation pending the PTAB's institution decision, arguing that a stay would simplify issues and conserve judicial and party resources. (MDL No. 3218, D.I. 45). The defendants have opposed this motion, and it remains pending before Judge Mazzant. The outcome of the institution decision will be a major turning point, as PTAB institution often leads to district courts granting a stay.

4. Current Status and Next Steps (May 2026)

The 26-cv-00033 case against Recoil remains stayed and is effectively dormant at the individual level. The substantive litigation is occurring entirely within the MDL. The next significant events are:

• Judge Mazzant's Ruling on the Motion to Stay: A decision is expected in the coming months and will determine whether the district court case proceeds in parallel with the PTAB review.
• PTAB Institution Decision (by October 2026): This is the most critical near-term event. If the PTAB institutes the IPR, the district court litigation is highly likely to be stayed until the PTAB issues a final written decision on the patent's validity, a process that typically takes 12 months from institution. If the PTAB denies institution, the stay motion will be moot, and the MDL will proceed to claim construction.

No claim construction (Markman) hearing has been scheduled, and no significant discovery has taken place, as all proceedings are awaiting the resolution of the pending stay motion and the PTAB's institution decision. The ultimate outcome for Recoil, LLC—whether through settlement, a dispositive motion, or trial—is contingent on the global rulings made in MDL No. 3218 and the validity determination at the PTAB.

Counsel for Plaintiffs RARE BREED TRIGGERS, INC. and ABC IP, INC.

Based on appearances in this and other consolidated patent infringement cases filed by Rare Breed Triggers, the company has assembled a national litigation team from at least two law firms. The attorneys below have filed notices of appearance or motions to appear pro hac vice in the various related actions that are now part of the MDL.

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Fish & Richardson P.C.

This prominent intellectual property and patent litigation firm appears to be leading the litigation campaign for Rare Breed Triggers nationwide.

• Carl E. Bruce (Lead Counsel)

  • Firm & Location: Principal at Fish & Richardson P.C., Dallas, Texas.
  • Noted Experience: Bruce has extensive experience leading patent infringement cases in the Eastern District of Texas and other major patent venues across the country.

• Matthew A. Colvin (Of Counsel)

  • Firm & Location: Principal at Fish & Richardson P.C., Dallas, Texas.
  • Noted Experience: Colvin's practice focuses on complex patent litigation, and he has represented clients in a wide array of technologies before district courts and the PTAB.

• Benjamin J. Christoff (Of Counsel)

  • Firm & Location: Associate at Fish & Richardson P.C., Minneapolis, Minnesota.
  • Noted Experience: Christoff focuses on patent litigation and has been involved in multiple actions on behalf of Rare Breed Triggers.

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Wood Herron & Evans LLP

This Cincinnati-based intellectual property boutique appears to handle the underlying patent prosecution and provides related litigation support.

• Glenn D. Bellamy (Of Counsel)
  • Firm & Location: Partner at Wood Herron & Evans LLP, Cincinnati, Ohio.
  • Noted Experience: Bellamy's practice includes patent prosecution, litigation, and client counseling; court filings from defendants in a related case have accused Bellamy of violating a court-ordered prosecution bar.

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Local Counsel

It is standard practice in the Eastern District of Texas to retain local counsel. While a specific notice of appearance for a local attorney in the 26-cv-00033 case is not publicly available due to the MDL consolidation, counsel from firms in the district would be expected to file an appearance. No such appearance is yet identifiable from the available records.

Counsel for Defendant RECOIL, LLC

As of May 7, 2026, counsel for the defendant, Recoil, LLC, has not formally appeared in the individual case docket (2:26-cv-00033). This is expected, as the case was consolidated into multidistrict litigation (MDL) shortly after it was filed. All substantive legal work, including the filing of appearances and responsive pleadings, is being managed centrally in the MDL proceeding, In re: Forced-Reset Trigger Patent Litigation, MDL No. 3218.

Based on filings within the MDL, a consortium of law firms is representing the various defendants, including Recoil, LLC. The specific attorneys who will be primarily responsible for Recoil, LLC are not yet individually designated, but the following attorneys and firms have filed notices of appearance on behalf of the consolidated defendant group and are understood to be representing Recoil, LLC's interests.

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Polsinelli PC

This national law firm is known for its robust intellectual property and patent litigation practice and appears to be taking a leading role for the defendants' consortium in the MDL.

• Michael D. Pegues (Lead Counsel for Defendants' Group)

  • Firm & Location: Senior Partner at Polsinelli PC, Dallas, Texas.
  • Noted Experience: Pegues is a veteran patent trial lawyer with extensive experience in the Eastern District of Texas, having litigated numerous high-stakes technology and patent cases.

• Jay E. Heidrick (Counsel for Defendants' Group)

  • Firm & Location: Shareholder and Intellectual Property Litigation Chair at Polsinelli PC, Kansas City, Missouri.
  • Noted Experience: Heidrick has a national practice focused on patent, trademark, and copyright litigation across a wide range of industries.

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Butler Snow LLP

This large, full-service law firm has a significant presence in the southern United States and brings substantial patent litigation experience to the defense group.

• Kurt G. Calia (Counsel for Defendants' Group)
  • Firm & Location: Partner at Butler Snow LLP, Austin, Texas.
  • Noted Experience: Calia's practice concentrates on intellectual property litigation, and he has represented clients in complex patent disputes involving diverse technologies in federal courts throughout Texas.

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Local Counsel

While lead counsel from Polsinelli's Dallas office are admitted to practice in the Eastern District of Texas, it is common for a firm based within the district to be retained. As of now, no specific local counsel has been designated solely for Recoil, LLC, with the MDL appearances by Texas-based attorneys from the lead firms serving this function for the entire group.

No filings are sealed, but the case-specific docket for Recoil, LLC remains sparse. All significant attorney appearances and activities are being recorded on the main docket for MDL No. 3218.