Rare Breed Triggers Inc et al. v. Z3 Productions LLC

In a legal battle brewing in the contentious market for high-performance firearm accessories, operating company Rare Breed Triggers, Inc. and its patent-holding affiliate, ABC IP, LLC, have filed a patent infringement lawsuit against competitor Z3 Productions, LLC. The plaintiffs, known for manufacturing and selling forced-reset triggers (FRTs) for AR-15 style rifles, allege that Z3 Productions' "Super Safety" trigger mechanism infringes on their intellectual property. Forced-reset triggers are designed to dramatically increase a semi-automatic firearm's rate of fire by using the energy from the reciprocating bolt carrier to mechanically reset the trigger, allowing for faster subsequent shots. The lawsuit asserts two patents: U.S. Patent No. 12,031,784, which covers an "Adapted forced reset trigger" with a specific locking device, and U.S. Patent No. 12,038,247, for a "Firearm trigger mechanism" featuring a three-position selector for safe, standard semi-automatic, and forced-reset modes.

The case was filed on April 13, 2026, in the U.S. District Court for the Eastern District of Texas and is assigned to Judge Amos L. Mazzant. This venue is significant, as the Eastern District of Texas has a long-standing reputation as a preferred forum for patent plaintiffs due to its experienced judges and expedited trial schedules, and it has recently resurged as the nation's busiest patent court. Judge Mazzant is a veteran of complex patent disputes and is known for his active case management. The litigation is notable not just as a dispute between competitors, but for its timing. It follows a tumultuous period where the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) classified some FRTs as illegal machineguns, a position that was successfully challenged in court. A May 2025 settlement between the government and Rare Breed Triggers resolved the regulatory battle, reportedly requiring the company to enforce its patents against copycat designs to ensure public safety. This suit against Z3 Productions appears to be part of that broader enforcement effort, signaling a shift from fighting federal regulators to battling market competitors for control of this now-legitimized firearm accessory technology.

As of May 4, 2026, the patent infringement litigation between Rare Breed Triggers Inc. and Z3 Productions LLC is in its nascent stages, with its trajectory now governed by its inclusion in a newly formed Multidistrict Litigation (MDL) proceeding.

Background and Litigation Campaign

This case is part of a widespread patent enforcement campaign initiated by Rare Breed Triggers and its intellectual property holding company, ABC IP LLC. The campaign began after Rare Breed reached a settlement with the U.S. Department of Justice on May 16, 2025, concluding extensive litigation over whether its "forced reset trigger" (FRT) products were illegal machine guns. A key component of that settlement required Rare Breed to enforce its patents against potential infringers. Subsequently, Rare Breed and ABC IP filed numerous lawsuits across the country against various competitors marketing and selling FRT devices, most notably products known as the "Super Safety."

Filing and Transfer to Multidistrict Litigation (MDL)

The lawsuit against Z3 Productions was originally filed in the Western District of Oklahoma (Case No. 5:25-cv-00695). On March 24, 2026, while still in Oklahoma, the plaintiffs filed a motion for leave to amend their complaint.

Recognizing the growing number of similar cases, several defendants filed a motion with the Judicial Panel on Multidistrict Litigation (JPML) to centralize the proceedings. On 2026-04-02, the JPML issued a transfer order creating MDL No. 3176. The litigation was initially captioned IN RE: SUPER SAFETY PATENT LITIGATION but was quickly renamed IN RE: RARE BREED TRIGGERS PATENT LITIGATION.

The JPML transferred all related cases to the U.S. District Court for the Eastern District of Texas for coordinated or consolidated pretrial proceedings and assigned them to Chief Judge Amos L. Mazzant, III. The case against Z3 Productions was officially transferred and docketed in the Eastern District of Texas as Case No. 4:26-cv-00367 on 2026-04-13.

Initial Pleadings and Current Posture

As of early May 2026, the case is procedurally in its infancy.

• Complaint: The operative complaint accuses Z3 Productions of infringing U.S. Patent Nos. 12,031,784 and 12,038,247 by selling its "Super Safety" product, which is described as a three-position selector enabling safe, standard semi-automatic, and forced-reset modes of operation.
• Answer: There is no record of Z3 Productions having filed an answer or any other responsive pleading. This is expected, as the transfer to the MDL likely stays individual case deadlines pending an order from the MDL judge setting a master pleading schedule for all defendants.
• Pending Motions: The plaintiffs' motion to amend the complaint, filed pre-transfer, is likely considered moot and will need to be re-urged within the MDL proceeding if plaintiffs wish to pursue it, per local court rules regarding transferred cases.

The litigation is currently awaiting Judge Mazzant's initial case management orders in the main MDL docket (4:26-md-03176), which will dictate the schedule for all pretrial matters, including answers, discovery, and claim construction.

Parallel PTAB Proceedings

There is no record of Z3 Productions LLC having filed an inter partes review (IPR) petition against the asserted patents at the Patent Trial and Appeal Board (PTAB).

However, a highly relevant IPR was filed by another defendant in the broader litigation campaign, Atrius Development Group Corp., challenging the validity of the '247 patent (one of the two patents asserted against Z3).

• IPR2025-01473: Filed by Atrius Development Group Corp. on 2025-08-29.
• Outcome: The PTAB issued a decision on 2026-02-17 denying institution of the IPR.

This outcome is a significant early victory for the plaintiffs, Rare Breed and ABC IP. The PTAB's refusal to institute a review strengthens the '247 patent's presumption of validity and weakens the ability of defendants in the MDL, including Z3 Productions, to argue for a stay of the district court case pending a PTAB review of that patent.

Summary and Outlook

The case is in a preliminary, pre-discovery phase and is now consolidated within MDL No. 3176. All significant legal developments for Z3 Productions will occur within the framework of the coordinated proceedings managed by Judge Mazzant in the Eastern District of Texas. The denial of the IPR petition on the '247 patent removes a potential roadblock for the plaintiffs and places pressure on the defendants involved in the MDL. The next steps will be determined by the court's initial scheduling orders for the consolidated litigation.

As of May 4, 2026, counsel from Fish & Richardson P.C. have formally appeared on behalf of plaintiffs Rare Breed Triggers Inc. and ABC IP LLC in case number 4:26-cv-00367. Attorneys from other firms have also appeared for the plaintiffs in highly similar, coordinated cases that are part of a multidistrict litigation (MDL) proceeding.

Fish & Richardson P.C.

• Name: Matt A. Colvin

  • Role: Lead Counsel
  • Firm & Office: Fish & Richardson P.C., Dallas, Texas
  • Noteworthy Experience: Colvin has appeared as counsel for Rare Breed Triggers and ABC IP in numerous patent infringement cases targeting sellers of "forced reset trigger" devices across the country.

• Name: Benjamin Christoff

  • Role: Of Counsel
  • Firm & Office: Fish & Richardson P.C., Minneapolis, Minnesota
  • Noteworthy Experience: Christoff has filed notices of appearance in this case and several other related patent cases alongside lead counsel Matt Colvin.

• Name: Carl Edward Bruce

  • Role: Of Counsel
  • Firm & Office: Fish & Richardson P.C., Dallas, Texas
  • Noteworthy Experience: Bruce is actively involved in the consolidated Rare Breed Triggers patent litigation, having appeared in multiple related cases transferred to the Eastern District of Texas.

Wood Herron & Evans LLP

• Name: Glenn Dean Bellamy
  • Role: Of Counsel
  • Firm & Office: Wood Herron & Evans LLP, Cincinnati, Ohio
  • Noteworthy Experience: Bellamy is listed as counsel for the plaintiffs in related cases that were transferred into the multidistrict litigation docket, indicating his role in the broader litigation campaign.

This case is part of the In re: MDL 3176 Rare Breed Triggers Patent Litigation, where numerous similar lawsuits have been centralized in the Eastern District of Texas for coordinated pretrial proceedings under Judge Amos L. Mazzant. The attorneys listed are representing the plaintiffs across this sprawling litigation effort. No local counsel has formally appeared on the docket for this specific case as of this date.

As of May 4, 2026, counsel for the defendant, Z3 Productions LLC, has not yet filed a notice of appearance in the case of Rare Breed Triggers Inc et al. v. Z3 Productions LLC, 4:26-cv-00367.

A review of the public court docket reveals only filings by the plaintiffs and administrative entries related to the case's transfer to the U.S. District Court for the Eastern District of Texas on April 13, 2026. Given that the case was initiated in this venue less than a month ago, it is likely that the defendant is still in the process of retaining counsel or that the formal appearance has not yet been entered into the court's record.

No attorneys are currently listed for Z3 Productions LLC on the official dockets, and no information is available in the public domain regarding their legal representation for this specific matter.