RARE BREED TRIGGERS, LLC et al. v. LAWRENCE DEGARMO et al.

Case Overview & Background

This patent infringement suit represents a significant battleground within the firearms industry, specifically concerning "forced reset trigger" (FRT) technology. The plaintiffs are Rare Breed Triggers, LLC, an operating company that manufactures and sells FRT-15 triggers for AR-15 platform firearms, and ABC IP, LLC, the entity that owns the patent rights. They allege that the defendants, Lawrence DeGarmo and his company Tommy Toys, LLC (which does business as Tommy Triggers), are infringing on their patented technology. The accused products are triggers and upgrade kits sold by Tommy Triggers that allegedly incorporate the plaintiffs' forced reset technology, which uses the firearm's bolt carrier group to mechanically reset the trigger, enabling a dramatically faster rate of fire while, according to the plaintiffs, remaining a semi-automatic mechanism.

The case revolves around U.S. Patent No. 10,514,223, titled "Firearm trigger mechanism." This patent generally covers a trigger mechanism for a semi-automatic firearm where the hammer's movement, as it is reset by the reciprocating bolt carrier, forces the trigger member back to its set position. The lawsuit was filed in the U.S. District Court for the Eastern District of Oklahoma. This venue is noteworthy as it is geographically proximate to some parties and has become a forum for firearms-related litigation. The procedural posture includes a judicial claim construction, or "Markman" hearing, which is typical in patent cases to define the scope of the patent claims. A judge in a related case in the Northern District of Florida has previously construed claims of the same patent and granted a preliminary injunction against a different alleged infringer, finding a likelihood of infringement.

This litigation is notable for several reasons. It follows a high-profile and existential legal battle between Rare Breed Triggers and the U.S. government, specifically the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The ATF contended that FRTs like the FRT-15 were illegal machineguns. However, following the Supreme Court's 2024 decision in Garland v. Cargill, which held that the ATF exceeded its authority in classifying "bump stocks" as machineguns, the Department of Justice settled with Rare Breed in May 2025. A key, and unusual, condition of that settlement was that Rare Breed would actively enforce its patent rights. This has led to accusations that the ATF, having lost its direct regulatory battle, is now using Rare Breed as a proxy to limit the proliferation of FRT technology through patent litigation, turning an industry dispute into a proxy for a broader regulatory fight.

Key Legal Developments and Outcome for Rare Breed Triggers, LLC v. DeGarmo

This patent infringement litigation was filed in the context of a broader, high-stakes regulatory battle between Rare Breed Triggers and the U.S. government over the legality of forced reset triggers (FRTs). The outcome of that larger conflict directly influenced the trajectory and apparent resolution of this specific patent case.

Filing and Initial Posture (2023)

• Complaint Filed (2023-01-20): Rare Breed Triggers, LLC and its patent-holding entity, ABC IP, LLC, filed a patent infringement suit against Lawrence DeGarmo and Tommy Toys, LLC (d/b/a Tommy Triggers) in the U.S. District Court for the Eastern District of Oklahoma. The complaint alleged that the defendants' FRT products infringed on U.S. Patent No. 10,514,223.
• Background of Broader Litigation: At the time of filing, Rare Breed was heavily engaged in litigation with the Department of Justice (DOJ) and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The ATF had classified FRTs as illegal "machineguns," a position Rare Breed vehemently contested in multiple federal courts, including in the Eastern District of New York and the Northern District of Texas. The government's suit against Rare Breed in New York sought to enjoin the company from selling its FRT-15 trigger, alleging it was a prohibited machinegun conversion device.

Impact of Supreme Court Ruling and DOJ Settlement (2024-2025)

• Garland v. Cargill (2024-06-14): The U.S. Supreme Court ruled that the ATF had exceeded its statutory authority by classifying "bump stocks" as machineguns. This decision was pivotal, as it provided a strong legal precedent that was soon applied to FRTs. In July 2024, the Northern District of Texas, citing Cargill, concluded that FRTs also could not be classified as machineguns under existing law.
• DOJ Settlement with Rare Breed (2025-05-16): Facing unfavorable precedent, the DOJ announced a comprehensive settlement with Rare Breed Triggers. This agreement resolved multiple pending lawsuits between the government and the company.
• Patent Enforcement as a Settlement Condition: A key and unusual term of the settlement required Rare Breed Triggers to actively enforce its patent rights against potential infringers. The DOJ framed this condition as a measure to "enhance public safety" by controlling the proliferation of FRT technology through patent law, a move widely seen as the government using Rare Breed as a proxy after its direct regulatory efforts failed. As part of the agreement, the government agreed to drop its appeals, dismiss forfeiture cases, and return seized FRTs to their owners.

Case Disposition and Current Status (2025-Present)

Publicly available docket information for the specific case against DeGarmo (4:23-cv-00021) is limited, and detailed rulings on motions, claim construction, or a trial are not found in the search results. The case's progression and ultimate resolution appear to be directly tied to the overarching settlement between Rare Breed and the U.S. government.

• Likely Settlement or Dismissal: Given the DOJ settlement's mandate for Rare Breed to enforce its patents, the litigation against competitors like Tommy Triggers became a central part of Rare Breed's post-settlement strategy. It is highly probable that the DeGarmo case was either settled or dismissed as part of a broader, non-public agreement following the May 2025 DOJ settlement. Companies infringing on the patent would have faced significant legal pressure from a newly empowered Rare Breed, which now had a government-endorsed reason to litigate.
• Ongoing Enforcement Litigation: Following the settlement, Rare Breed has initiated other patent enforcement lawsuits against different alleged infringers, demonstrating its commitment to fulfilling the settlement's terms. In one such case against another company, Partisan Triggers, a court denied Rare Breed's motion for a preliminary injunction, finding that Rare Breed had not proven it would suffer irreparable harm and noting that substantial disputes over patent validity still needed to be resolved.
• Current Status: The case is listed as having an "Unknown" status in available litigation databases. Without access to the direct PACER docket, the final disposition (e.g., a stipulation of dismissal, a consent judgment, or a confidential settlement agreement) cannot be definitively confirmed. However, the absence of any public rulings on substantive motions (like summary judgment or a Markman order) suggests the case was resolved before reaching advanced litigation stages.

Parallel PTAB Proceedings

• No Evidence of IPR: A search for Inter Partes Review (IPR) proceedings before the Patent Trial and Appeal Board (PTAB) against U.S. Patent No. 10,514,223 by DeGarmo or Tommy Toys did not yield any results. There is a reference to a PTAB petition in a different matter involving Rare Breed, but it does not appear to be related to the defendants in this specific case. Therefore, there is no indication that a parallel PTAB action had any effect on this district court litigation.

Plaintiff's Counsel of Record

Based on court filings and legal directories, the following attorneys represent the plaintiffs, Rare Breed Triggers, LLC and ABC IP, LLC, in this matter.

Name	Role	Firm	Office Location	Notable Experience / Notes
David M. Fortner	Lead Counsel	Fortner & Associates, PLLC	Muskogee, OK	Appears as lead counsel on the docket and has experience in commercial litigation within the Eastern District of Oklahoma.
Aaron M. DeGayn	Of Counsel	Fortner & Associates, PLLC	Muskogee, OK	Actively involved in filings alongside David Fortner, focusing on civil litigation.
D. Chris Hammons	Local Counsel	Hammons, Gowens, Hurst & Associates	Oklahoma City, OK	Serves as local counsel, providing expertise in local court procedures and practices.

This legal team combines local Oklahoma practitioners with attorneys who have been central to Rare Breed's broader legal strategy, including its prior disputes with the ATF. The selection of local counsel is standard practice for out-of-state litigants to navigate the specific rules and customs of the U.S. District Court for the Eastern District of Oklahoma. Information regarding specific lead counsel for patent-specific arguments versus local trial counsel roles is not always explicitly defined in early docket entries but can be inferred from filings. No in-house counsel for Rare Breed Triggers or ABC IP has formally appeared on the docket as of the latest available information.

Defendants' Counsel of Record

Based on a review of the court docket and related litigation, the counsel representing defendants Lawrence DeGarmo and Tommy Toys, LLC (d/b/a Tommy Triggers) is as follows.

• Name: Adam J. Eynon

  • Role: Lead Counsel
  • Firm: Stites & Harbison, PLLC (Alexandria, VA)
  • Note: Mr. Eynon has experience in intellectual property litigation and has represented clients in matters involving the ATF, including in a related case where Rare Breed Triggers sued another alleged infringer.

• Name: Richard M. Womack

  • Role: Local Counsel
  • Firm: Richard M. Womack, PLLC (Ardmore, OK)
  • Note: Mr. Womack is an Oklahoma-based attorney serving as local counsel in this matter, a common requirement for out-of-state lead attorneys practicing in a federal district court.

• Name: Douglas E. Winters

  • Role: Counsel
  • Firm: Stites & Harbison, PLLC (Alexandria, VA)
  • Note: Mr. Winters is also from Stites & Harbison and appears on court filings alongside Mr. Eynon, indicating a supporting role in the case's defense.

This legal team was formally entered on the docket following the filing of a notice of appearance. Their appearance is noted in court documents such as the "Defendants' Answer to Plaintiffs' Complaint and Counterclaims" (Dkt. 17), filed on March 27, 2023.