Rare Breed Triggers Inc et al. v. Tyler Harrison et al.

This patent infringement case represents a new front in the legal battles surrounding "forced-reset triggers" (FRTs), devices that significantly increase the firing speed of semi-automatic rifles. The plaintiffs are Rare Breed Triggers, Inc., an operating company known for its popular FRT-15 trigger, and ABC IP LLC, a related entity that holds the patents and licenses them exclusively to Rare Breed. They are suing Tyler Harrison and his company, Harrison Gunworks LLC, a gunsmithing and parts business based in Pocatello, Idaho. The lawsuit alleges that Harrison Gunworks' "Super Safety" product, which is described as an "active assisted-reset mechanism" that helps the trigger return forward after each shot, infringes on five of the plaintiffs' patents. This technology is at the center of a contentious debate over firearm regulations, as it allows for firing rates approaching those of automatic weapons while arguably remaining semi-automatic.

The five patents asserted by Rare Breed and ABC IP all relate to the core technology of mechanically resetting a firearm's trigger using the motion of the bolt carrier or hammer. The patents at issue are: 12,274,807, for a trigger with a three-position selector for safe, standard semi-automatic, and forced-reset modes; 11,724,003 and 12,036,336, which describe similar three-position mechanisms with a locking member; 12,038,247, which details a trigger using a cam to force the reset; and 10,514,223, covering a mechanism where the hammer forces the trigger reset and a locking bar prevents premature firing. The case (4:26-cv-00379) is before Judge Amos L. Mazzant in the Eastern District of Texas, a popular and experienced venue for patent litigation. The case was filed on April 14, 2026, after being transferred from the District of Idaho.

This litigation is particularly notable due to its market context. Rare Breed Triggers recently emerged from a high-profile legal fight with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which had classified its FRT-15 product as an illegal machine gun. Following a Supreme Court ruling on a similar technology (bump stocks) in Cargill v. Garland, the Department of Justice settled its litigation with Rare Breed in May 2025. A key condition of that settlement requires Rare Breed to enforce its patents to prevent infringement. This lawsuit against Harrison Gunworks, therefore, appears to be a direct consequence of that agreement, signaling Rare Breed's strategy to use its patent portfolio to control the market for FRT technology now that its legality has been affirmed. The outcome of this case and others like it will likely shape the competitive landscape for these controversial firearm accessories.

Key Legal Developments and Outcome

As of May 4, 2026, the patent infringement litigation involving Rare Breed Triggers and Harrison Gunworks is in its early stages, having been recently consolidated into a larger multidistrict litigation (MDL). A significant parallel proceeding at the Patent Trial and Appeal Board (PTAB) has concluded in the patent owner's favor, strengthening its position in the district court case.

Pre-Trial and Consolidation Chronology

• Initial Filing and Pleadings (District of Idaho): The case was originally filed by Rare Breed Triggers and ABC IP in the U.S. District Court for the District of Idaho as Case No. 4:25-cv-00299. Following the complaint, defendants Tyler Harrison and Harrison Gunworks LLC filed an Amended Answer to the Complaint which included counterclaims against the plaintiffs.

• Multidistrict Litigation (MDL) Transfer (2026-04-02): The Judicial Panel on Multidistrict Litigation (JPML) issued a transfer order to consolidate the Idaho case with five other similar lawsuits filed by Rare Breed against various defendants. The JPML found that centralization was necessary to avoid duplicative discovery and prevent inconsistent pre-trial rulings, particularly on claim construction and patent validity. The consolidated action was officially named In re: Rare Breed Triggers Patent Litigation, assigned MDL No. 3176, and transferred to the U.S. District Court for the Eastern District of Texas.

• Assignment to Judge Amos L. Mazzant (2026-04-14): Upon its transfer to the Eastern District of Texas, the Harrison Gunworks case was assigned case number 4:26-cv-00379 and, along with the other consolidated cases, was assigned to Judge Amos L. Mazzant, an experienced patent litigation judge. Any motions that were pending in the Idaho court at the time of transfer are considered moot and must be re-filed with the Texas court to be considered.

• Current Posture (Active): The case remains in its initial stages before Judge Mazzant. As of early May 2026, the court has not yet issued a comprehensive initial case management or scheduling order for the MDL that would set deadlines for consolidated pleadings, discovery, or claim construction. Such an order is expected in the near future and will dictate the procedural path for all consolidated cases, including the one against Harrison Gunworks.

Parallel PTAB Proceedings

A key development has occurred outside of the district court. At least one of the asserted patents, U.S. Patent No. 12,038,247, which covers a trigger mechanism with a three-position selector, has survived a validity challenge at the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB).

• IPR Petition Filing (2025-08-29): Atrius Development Group Corp., one of the defendants in the broader litigation effort by Rare Breed, filed a petition for inter partes review (IPR) against the '247 patent. The petition, docketed as IPR2025-01473, argued that all 23 claims of the patent were obvious in light of prior art.

• Arguments for and Against Institution: The petitioner, Atrius, argued that existing prior art taught the key elements of the forced-reset trigger and that combining it with a known three-position selector would have been obvious. In response, the patent owner (ABC IP / Rare Breed) filed a request for discretionary denial. They argued that they had "strong settled expectations" in the patent's validity following their extensive and costly legal battle with the U.S. Government, which culminated in the May 2025 settlement requiring them to enforce their patents. They also asserted that the examiner had already considered the primary prior art references during the patent's prosecution.

• Institution Denied (2026-02-18): In a significant victory for the plaintiffs, the PTAB denied institution of the IPR on the merits. This decision means the PTAB determined there was not a "reasonable likelihood" that the petitioner would succeed in proving the patent's claims were invalid. The '247 patent therefore remains valid and enforceable, strengthening the plaintiffs' position in the MDL. This outcome will likely deter other defendants, including Harrison Gunworks, from filing their own IPRs on similar grounds against this patent.

No parallel PTAB proceedings have been identified for the other four patents at issue in this case (12,274,807; 11,724,003; 12,036,336; and 10,514,223).

Substantive Motions, Discovery, and Outcome

The litigation is not yet advanced enough for substantive pre-trial motions, claim construction, significant discovery milestones, or trial. No motions to dismiss or for summary judgment have been filed in the consolidated MDL. The case remains open and active, with the next steps awaiting the initial scheduling order from Judge Mazzant.

Counsel for Plaintiffs Rare Breed Triggers Inc. and ABC IP LLC

As this case is part of a newly consolidated multidistrict litigation (MDL), the legal team for plaintiffs Rare Breed Triggers and ABC IP LLC includes attorneys from multiple firms who were initially involved in the individual cases filed across various districts. While a formal lead counsel structure for the MDL has not yet been ordered by the court, the attorneys who have appeared on the docket represent the core of the plaintiffs' national litigation team.

Lead Counsel (Anticipated)

• Name: John R. Keville

  • Role: Lead Counsel
  • Firm: Sheppard Mullin Richter & Hampton LLP (Houston, TX)
  • Note: Keville is a highly-regarded, Band 1-ranked patent trial lawyer with decades of experience representing both plaintiffs and defendants in complex technology cases across the country. He is the managing partner of his firm's Houston office and has argued before the U.S. Court of Appeals for the Federal Circuit.

• Name: Glenn D. Bellamy

  • Role: Lead Counsel
  • Firm: Wood Herron & Evans LLP (Cincinnati, OH)
  • Note: Bellamy has appeared as counsel for the plaintiffs in multiple related cases that have now been transferred into the MDL, indicating a central coordinating role in the litigation.

Of Counsel

• Name: Carl E. Bruce

  • Role: Of Counsel
  • Firm: Fish & Richardson P.C. (San Diego, CA)
  • Note: Bruce appeared pro hac vice in the original Idaho case and other related actions, suggesting a key role on the national team, likely focused on patent-specific or strategic aspects of the litigation.

• Name: Matthew A. Colvin

  • Role: Of Counsel
  • Firm: Fish & Richardson P.C. (Minneapolis, MN)
  • Note: Colvin, like his colleague from Fish & Richardson, has been admitted pro hac vice in several of the consolidated cases, pointing to his active involvement in the national strategy.

• Name: Ben Christoff

  • Role: Of Counsel
  • Firm: Fish & Richardson P.C. (Minneapolis, MN)
  • Note: Christoff has also filed for pro hac vice admission alongside other members of the Fish & Richardson team, rounding out the firm's representation for the plaintiffs.

Local Counsel

• Name: Jared Wayne Allen
  • Role: Local Counsel
  • Firm: The Kubecka Law Firm, PLLC (Sherman, TX)
  • Note: Allen appeared on behalf of the plaintiffs in the original filings in the District of Idaho before the case was transferred to the Eastern District of Texas. Given his location in the transferee district, he is positioned to serve as local counsel for the MDL.

Defendant's Counsel of Record

As of May 4, 2026, attorneys who represented the defendants in the original proceedings in the District of Idaho have been identified. However, since the case was transferred to the Eastern District of Texas for Multidistrict Litigation (MDL) and all prior motions were terminated upon transfer, new notices of appearance in Texas are required. Based on available docket information for Case No. 4:26-cv-00379, the following attorneys represented the defendants prior to the MDL transfer and are anticipated to continue representation.

Lead Counsel

• Name: John M. Skeriotis
• Role: Lead Counsel
• Firm: Emerson Thomson Bennett, LLC (Akron, OH)
• Note: Skeriotis chairs his firm's litigation practice and has specific experience in patent litigation related to forced-reset trigger technology. A motion for his pro hac vice appearance was filed in the Idaho proceedings.

Additional Counsel

• Name: Joyce Ann Hemmer
• Role: Of Counsel
• Firm: Elam & Burke P.A. (Boise, ID)
• Note: Hemmer is a defense litigator with experience serving as local counsel for out-of-state attorneys and handled the initial answer and corporate disclosures in the Idaho case.

Local Counsel (Texas)

As of this date, no Texas-based local counsel has filed a notice of appearance on behalf of defendants Tyler Harrison or Harrison Gunworks LLC in the consolidated MDL case in the Eastern District of Texas. The appearance of local counsel is expected to be required for out-of-state attorneys, like Mr. Skeriotis, to practice before the court.