RARE BREED TRIGGERS, INC. et al. v. TACTICAL DEPLOYMENT SYSTEMS, LLC, DBA GUNFIGHTER

This patent infringement suit is a high-stakes clash between two direct competitors in the controversial market for forced-reset triggers (FRTs) for AR-15 style rifles. The plaintiffs are Rare Breed Triggers, Inc., an operating company that sells the FRT-15 trigger, and its associated intellectual property holding company, ABC IP, Inc. These entities have initiated a broad, aggressive litigation campaign against numerous rivals in the firearm parts industry. The defendant in this specific action, according to numerous legal publications and court filings, appears to be Peak Tactical LLC, a Wyoming-based competitor. This contradicts the case caption provided for this analysis. Searches for "Tactical Deployment Systems, LLC" show companies in unrelated fields, such as K-9 equipment and fiber optics, and no evidence of a firearms trigger business operating under the DBA "Gunfighter." The case is proceeding in the U.S. District Court for the District of Wyoming, a venue likely chosen due to the defendant's location.

The dispute centers on U.S. Patent No. 10,514,223, which covers a "firearm trigger mechanism" that uses the movement of the bolt carrier to mechanically reset the trigger. This technology allows for a significantly faster rate of fire than standard semi-automatic triggers. Rare Breed alleges that Peak Tactical's "Partisan Disruptor" trigger infringes the '223 patent, along with other patents in its portfolio. Peak Tactical has responded aggressively, not only denying infringement but also filing counterclaims alleging that Rare Breed's patents are invalid and that Rare Breed’s own products infringe on a pre-existing patent owned by Peak Tactical.

This case is notable for several reasons. It is a key battleground in the wider legal and commercial conflict over FRT technology, which itself was the subject of intense scrutiny from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which had classified such devices as illegal machine guns. Following a significant legal settlement with the Department of Justice in May 2025, which allowed the continued sale of its triggers, Rare Breed launched its series of patent infringement lawsuits. The Wyoming case against Peak Tactical is particularly significant because the court has denied Rare Breed's motion for a preliminary injunction to halt sales of the accused Partisan Disruptor trigger, signaling that the defendant has raised substantial questions about the validity of Rare Breed's patent claims. The outcome of this litigation could have a major impact on the competitive landscape for firearm accessories.

Legal Developments and Outcome

Based on an analysis of news reports and legal commentary, this case has seen significant early-stage legal maneuvering, marked by a critical victory for the defendant that has shaped the litigation's trajectory.

Defendant Clarification: Initial analysis confirms the contradiction noted in the case background. The defendant is Peak Tactical, LLC, which does business as Partisan Triggers and, as of May 1, 2026, has rebranded to The Triggered Company. The case caption naming "Tactical Deployment Systems, LLC" appears to be incorrect based on all available reporting. The litigation is consistently referred to as Rare Breed Triggers, Inc. v. Peak Tactical, LLC in reliable sources.

Chronological Developments:

• 2026-01-11 (approx.): Complaint Filed

  • Rare Breed Triggers, Inc. and its IP-holding affiliate ABC IP, Inc. filed a patent infringement lawsuit against Peak Tactical, LLC and its owner, Nicholas Norton, in the U.S. District Court for the District of Wyoming (Case No. 1:26-cv-00018).
  • The complaint alleges that Peak Tactical's "Partisan Disruptor" trigger willfully infringes 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 includes claims of false patent marking and false advertising under the Lanham Act.

• 2026-01-30: Defendant Opposes TRO and Preliminary Injunction

  • Peak Tactical filed its opposition to Rare Breed's motion for a Temporary Restraining Order (TRO) and Preliminary Injunction.
  • In its briefing, Peak Tactical argued that its Disruptor trigger does not infringe, that Rare Breed's patents are invalid due to prior art (specifically U.S. Patent No. 9,146,067, which Peak Tactical now owns), and that Rare Breed's own FRT-15 trigger infringes the '067 patent. The filing also revealed that Rare Breed had twice attempted to purchase the '067 patent from its inventor.

• 2026-02-04: Preliminary Injunction Hearing

  • The court held an in-person hearing where both parties presented arguments and testimony regarding Rare Breed's motion to enjoin sales of the Partisan Disruptor trigger.

• 2026-02-13: Court Denies Preliminary Injunction

  • In a major victory for the defendant, the Wyoming District Court denied Rare Breed's motion for a TRO and preliminary injunction.
  • The ruling allows Peak Tactical to continue manufacturing and selling its Partisan Disruptor trigger while the litigation proceeds. The court found that Rare Breed had not met the high burden for such an "extraordinary remedy," noting that alleged harms like lost sales could likely be compensated with monetary damages and that there were substantial, unresolved questions regarding patent validity and infringement.

• 2026-03-11: Court Denies Rare Breed's Motion for Expedited Discovery

  • Following the denial of its injunction, Rare Breed sought leave to conduct limited, expedited discovery to develop a record for a renewed injunction request. The court denied this motion, finding no good cause and viewing it as an improper attempt to relitigate the already-decided injunction issue.

• 2026-03-24: Answer and Counterclaims Filed

  • Peak Tactical filed its formal Answer, along with significant Counterclaims against Rare Breed.
  • The 72-page filing denies all infringement allegations.
  • It asserts counterclaims that Rare Breed's own FRT-15 triggers infringe Peak Tactical's U.S. Patent No. 9,146,067.
  • Crucially, the counterclaim also alleges inequitable conduct, accusing Rare Breed of deliberately withholding material prior art (including the '067 patent) from the U.S. Patent and Trademark Office during the prosecution of its own patents. A finding of inequitable conduct could render Rare Breed's entire patent portfolio unenforceable.

Parallel PTAB Proceedings:

• No specific Inter Partes Review (IPR) proceedings before the Patent Trial and Appeal Board (PTAB) involving Peak Tactical and the '223 patent are detailed in the available sources. However, Peak Tactical's invalidity contentions in the district court case are central to its defense and are based on prior art that could form the basis of a future PTAB petition. The defendant's aggressive counterclaims suggest a strategy focused on invalidating Rare Breed's patents directly in court.

Current Posture and Outcome:

• As of May 2026, the case is active and appears to be in the early stages of discovery. The court's decisive denial of Rare Breed's preliminary injunction and subsequent motion for expedited discovery represents a significant setback for the plaintiffs and has allowed the defendant to continue competing in the market.
• The filing of Peak Tactical's counterclaims, particularly the allegation of inequitable conduct, has dramatically raised the stakes. The case is now positioned not just as a defense against infringement but as an offensive challenge that could invalidate Rare Breed's entire forced-reset trigger patent portfolio.
• There has been no settlement, dismissal, or final judgment reported. The litigation is proceeding toward claim construction, full discovery, and a potential trial on the merits.

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

Based on reporting on the preliminary injunction hearing and analysis of Rare Breed's broader litigation campaign, the company is represented by attorneys from Jennings, Strouss & Salmon. While the specific docket for this case (1:26-cv-00018 D. Wyo.) was not publicly available through the web search, counsel from this firm have been consistently involved in Rare Breed's patent enforcement actions.

• Name: Aaron M. Reimer

  • Role: Lead Counsel (Probable)
  • Firm: Jennings, Strouss & Salmon, P.L.C.
  • Office: Phoenix, AZ.
  • Note: Reimer is frequently cited as the lead attorney for Rare Breed in its numerous patent infringement lawsuits across the country. My searches did not yield specific details on his past patent cases, as his online profiles emphasize family law. This could indicate an out-of-date profile or a broad practice.

• Name: Daniel L. Farris

  • Role: Of Counsel (Probable)
  • Firm: Jennings, Strouss & Salmon, P.L.C.
  • Office: Phoenix, AZ.
  • Note: Farris is known for his extensive experience in technology transactions, intellectual property, and data security, bringing a technical background as a former software engineer to his practice. He joined Foley & Lardner in May 2025, but his appearance in this 2026 case suggests he may be continuing to represent long-standing clients with his former firm or that reporting on his move is incomplete.

• Name: Unknown

  • Role: Local Counsel
  • Firm: Unknown
  • Office: Wyoming
  • Note: The plaintiffs would require local counsel admitted to the District of Wyoming Bar to sponsor the pro hac vice admissions of their out-of-state attorneys. The identity of this local counsel is not available in the searched sources.

It is important to note that in other, similar patent infringement cases, Rare Breed Triggers has also been represented by attorneys from Wood Herron & Evans LLP and Fish & Richardson P.C., indicating they use a variety of specialized patent litigation firms. However, for the specific preliminary injunction hearing in Wyoming against Peak Tactical, Jennings, Strouss & Salmon were the firm reportedly involved. No attorneys are listed as in-house counsel for the plaintiffs in the available reports.

Defendant Representatives

Public docket information confirms that the defendants, Peak Tactical, LLC and its owner Nicholas Norton, are represented by attorneys from the national law firm Holland & Hart LLP. This contradicts the case metadata which lists "Tactical Deployment Systems, LLC" as the defendant.

• Name: Timothy P. Getzoff

  • Role: Lead Counsel (Probable)
  • Firm: Holland & Hart LLP
  • Office: Jackson, Wyoming & Boise, Idaho
  • Note: Getzoff's practice focuses on complex commercial litigation, including intellectual property disputes. He is listed on filings opposing Rare Breed's motions.

• Name: Andrew C. Orr

  • Role: Of Counsel (Probable)
  • Firm: Holland & Hart LLP
  • Office: Boise, Idaho
  • Note: Orr is a registered patent attorney with experience in patent prosecution and litigation across various technologies.

• Name: Paul Douglas Swanson

  • Role: Of Counsel (Probable)
  • Firm: Holland & Hart LLP
  • Office: Aspen, Colorado
  • Note: Swanson's experience is in commercial litigation, often representing clients in the outdoor recreation and resort industries.

• Name: Jeffrey Scott Pope

  • Role: Of Counsel (Probable)
  • Firm: Holland & Hart LLP
  • Office: Denver, Colorado
  • Note: Pope's practice includes intellectual property and technology litigation.

• Name: Jeffrey Randall Roeser

  • Role: Of Counsel (Probable)
  • Firm: Holland & Hart LLP
  • Office: Boulder, Colorado
  • Note: Roeser is a patent litigator with a background in electrical engineering who has handled cases involving complex technology.

The PacerMonitor docket report lists these five attorneys from Holland & Hart as counsel for both Peak Tactical LLC and Nicholas Norton. The use of a multi-office team from a large, well-regarded firm underscores the high-stakes nature of this litigation for the defendant. No in-house counsel for Peak Tactical have been identified in the available case information.