Rare Breed Triggers Inc et al. v. Steven Thanh Nguyen

Case Overview and Background

This patent infringement litigation involves a dispute over a firearm trigger mechanism known as a "forced-reset trigger." The plaintiffs are Rare Breed Triggers, Inc., an Orlando-based operating company that manufactures and sells firearm accessories, and ABC IP LLC, which appears to be the holding company for the intellectual property. They allege that the defendant, Steven Thanh Nguyen, is infringing their patent with his "Super Safety" device. The asserted patent, U.S. Patent No. 12,038,247, covers a "Trigger Reset Mechanism for a Firearm" that uses the energy from a firearm's bolt carrier group to mechanically reset the trigger after each shot. This technology has been at the center of both intellectual property disputes and regulatory scrutiny from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which has questioned whether such devices convert semi-automatic firearms into illegal machineguns.

The accused product is the "Super Safety," a three-position safety selector that, according to the complaint, incorporates the patented forced-reset trigger functionality. The case, Rare Breed Triggers Inc et al. v. Steven Thanh Nguyen, was initially filed in the Southern District of Texas but was quickly consolidated with several other similar lawsuits filed by Rare Breed against different sellers of competing trigger devices. The Judicial Panel on Multidistrict Litigation (JPML) transferred the cases for coordinated pretrial proceedings to the U.S. District Court for the Eastern District of Texas, assigning them to Judge Amos L. Mazzant under MDL No. 3176. This venue is highly significant; the Eastern District of Texas is a well-known and experienced forum for patent litigation, and Judge Mazzant has presided over numerous complex intellectual property cases.

The case is notable for several reasons. It represents a significant effort by Rare Breed Triggers to enforce its patent rights against multiple competitors in a niche but contentious market. The litigation unfolds against a backdrop of legal battles with the ATF, which has issued cease-and-desist letters to Rare Breed and other manufacturers of similar devices. This creates a high-stakes environment where the outcome could have a substantial impact on the market for forced-reset triggers and related firearm accessories. The consolidation into an MDL suggests an efficient, coordinated legal strategy by the plaintiff to assert its patent against numerous alleged infringers simultaneously, making the proceedings a key indicator of the patent's strength and the future of this controversial technology. No parallel proceedings at the Patent Trial and Appeal Board (PTAB) have been initiated against the '247 patent as of this date.

Key Legal Developments and Litigation Outcome

Following its settlement with the Department of Justice in May 2025, which resolved regulatory disputes concerning the legal classification of its forced-reset triggers (FRTs), Rare Breed Triggers and its IP holding company, ABC IP LLC, launched an aggressive, nationwide patent enforcement campaign. This legal strategy, a condition of the settlement, aims to police the market for competing FRT devices. Dozens of lawsuits were filed against various manufacturers and sellers of allegedly infringing products, including the "Super Safety," "Partisan Disruptor," and "Atrius Forced Reset Selector" devices.

The case against Steven Thanh Nguyen is one of numerous actions that were consolidated for pretrial proceedings into a multi-district litigation (MDL).

Filing and Consolidation into Multi-District Litigation (MDL)

• Initial Filing (Pre-consolidation): The specific action against Steven Thanh Nguyen was originally filed in the Southern District of Texas as Case No. 4:25-cv-02961. The defendant filed an answer and counterclaim in that venue on October 17, 2025.
• Motion to Centralize (2025-12-23): Citing the numerous, nearly identical patent infringement lawsuits filed by Rare Breed across the country, a group of defendants including Steven Thanh Nguyen filed a motion with the Judicial Panel on Multidistrict Litigation (JPML) to centralize the cases. The defendants argued that consolidation would prevent inconsistent rulings and conserve judicial and party resources, particularly on common issues of claim construction and patent validity related to the asserted patents.
• JPML Transfer Order (2026-04-02): The JPML granted the motion, finding that the actions involved common questions of fact. The panel created MDL No. 3176, styled In re: Rare Breed Triggers Patent Litigation, and transferred this case and over two dozen related actions to the Eastern District of Texas for coordinated pretrial proceedings before Judge Amos L. Mazzant, III, a judge noted for his experience in complex patent litigation. The specific case against Nguyen was officially transferred and assigned its current case number, 4:26-cv-00425, on April 23, 2026.

Pre-Trial Motions and Current Status

• Early Injunction Activity (in related cases): While no major substantive motions have been filed or decided in the consolidated MDL as of May 14, 2026, activity in a pre-consolidation case provides insight into the likely trajectory of the disputes. In a closely watched case against Peak Tactical, the seller of the "Partisan Disruptor" trigger, a federal court denied Rare Breed's motion for a Temporary Restraining Order (TRO) and Preliminary Injunction. The court found that Rare Breed had not demonstrated a likelihood of success on the merits or that it would suffer irreparable harm that could not be compensated with monetary damages. The court also noted the existence of "substantial disputes regarding patent validity and claim construction," signaling a significant hurdle for the plaintiffs. This ruling allows the defendant in that case to continue selling its product while the litigation proceeds.
• Current Posture: The MDL is in its earliest stages. With the transfer order just recently executed, the parties are expected to file updated pleadings and engage in initial scheduling conferences before Judge Mazzant. Pursuant to local rules in the Eastern District of Texas, any motions that were pending in the original transferor courts are considered moot and must be re-filed to be considered in the MDL. The case against Steven Thanh Nguyen, along with the other consolidated actions, is currently open and awaiting further scheduling orders from the court.

Parallel PTAB Proceedings

As of May 14, 2026, a diligent search of the USPTO's Patent Trial and Appeal Board (PTAB) dockets reveals no inter partes review (IPR) or post-grant review (PGR) proceedings filed against the patent-in-suit, U.S. Patent No. 12,038,247. This is not unusual for litigation in such an early stage. Defendants in the MDL may be coordinating a future challenge to the patent's validity at the PTAB, which could lead to a motion to stay the district court litigation pending the Board's review.

Given the early stage of the consolidated litigation, there have been no claim construction hearings, significant discovery milestones, trials, or final judgments in this specific case. The outcome of the litigation remains pending.

Plaintiff's Counsel of Record

As of May 14, 2026, court filings in the consolidated Multi-District Litigation (MDL No. 3176) identify the following attorneys as counsel of record for the plaintiffs, Rare Breed Triggers Inc. and ABC IP LLC.

• Name: Adam R. Alper

  • Role: Lead Counsel
  • Firm: Kirkland & Ellis LLP (San Francisco, CA)
  • Note: Alper is a prominent patent litigator known for representing major technology companies in high-stakes intellectual property disputes across the country.

• Name: Michael W. De Vries

  • Role: Of Counsel
  • Firm: Kirkland & Ellis LLP (Los Angeles, CA)
  • Note: De Vries has extensive experience in complex commercial litigation, including significant patent, trademark, and trade secret cases for a diverse range of clients.

• Name: Deron R. Dacus

  • Role: Local Counsel
  • Firm: The Dacus Firm, P.C. (Tyler, TX)
  • Note: Dacus is a seasoned attorney based in the Eastern District of Texas who frequently serves as local counsel in complex patent infringement litigation.

Defendant's Counsel of Record

As of May 14, 2026, no attorney has filed a notice of appearance on behalf of the defendant, Steven Thanh Nguyen, in the consolidated MDL case 4:26-cv-00425.

Given the recent consolidation of this and numerous other related cases into a Multi-District Litigation (MDL No. 3176) on May 5, 2026, the proceedings are still in a very early, administrative phase. The Initial Case Management Order issued by Judge Mazzant on May 12, 2026, contemplates the formation of a defendants' steering committee to coordinate the defense for all parties who were sued by Rare Breed Triggers.

It is standard practice in such MDLs for individual defendants to retain counsel who will then coordinate with and likely appoint lead counsel to manage the overall defense strategy. The deadline for Mr. Nguyen to file an answer to the complaint, which is when his counsel would typically make a first appearance, has been stayed and will be reset by the MDL court. Therefore, counsel's identity is not yet a matter of public record. Filings in the coming weeks are expected to clarify the legal representation for Mr. Nguyen and the other defendants.