RARE BREED TRIGGERS, LLC et al. v. WIDE OPEN ENTERPRISES LLC et al.

Case Overview: A High-Stakes Firearms Technology Dispute

This patent infringement lawsuit pits two firearms accessory manufacturers, Rare Breed Triggers, LLC (an operating company) and its IP holding company ABC IP, LLC, against competitors Wide Open Enterprises LLC and Ottofirearms LLC. The conflict centers on a controversial and popular firearm technology: "forced-reset triggers" (FRTs). These devices replace the standard trigger in semi-automatic rifles like the AR-15 and use the force of the reciprocating bolt carrier group to mechanically reset the trigger after each shot. This allows for a dramatically increased rate of fire, approaching that of a fully automatic weapon, while arguably remaining technically semi-automatic as only one round is fired per pull of the trigger. The plaintiffs assert that the defendants' "Wide Open Trigger" (WOT) infringes on their U.S. Patent No. 10,514,223, which covers a "firearm trigger mechanism" with a locking bar that blocks the trigger from moving until the bolt carrier is in battery, a key feature of the FRT design.

Procedural Posture and Notability

The case was originally filed in the U.S. District Court for the Northern District of Ohio, a standard venue for patent disputes, and assigned to Senior District Judge James G. Carr. However, the procedural history has been shaped by parallel litigation across the country. In a related case in Florida, a federal judge granted Rare Breed a preliminary injunction, finding that the WOT was "plainly copied" from Rare Breed's FRT-15 trigger. More significantly, this case and others involving Rare Breed's patents were consolidated into a Multidistrict Litigation (MDL) proceeding. On April 14, 2026, the Judicial Panel on Multidistrict Litigation transferred related cases to the Eastern District of Texas under Judge Amos L. Mazzant to be managed as MDL 3176, styled In re: Rare Breed Triggers Patent Litigation. This consolidation is typical when multiple lawsuits involving the same patents and technology are filed in different districts, aiming to streamline pretrial proceedings and avoid conflicting rulings.

The litigation is notable for several reasons. It unfolds against a backdrop of intense legal and regulatory scrutiny of FRT technology by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which has contended that these devices are illegal machine guns. Rare Breed was engaged in separate, high-profile litigation with the U.S. government, which ultimately ended in a settlement in May 2025, where the Department of Justice agreed to not classify FRTs as machine guns. This settlement, however, reportedly included a condition that Rare Breed would actively enforce its patents. This patent infringement suit can therefore be seen as a direct consequence of that settlement, representing a shift from a regulatory battle for survival to a commercial battle for market dominance in a now-clarified, lucrative market for these performance-enhancing triggers.

Legal Developments & Case Status

Based on available docket information and litigation records, the legal proceedings in RARE BREED TRIGGERS, LLC et al. v. WIDE OPEN ENTERPRISES LLC et al. have been significantly influenced by parallel litigation and a broader, nationwide legal strategy by the plaintiffs.

Initial Proceedings and Preliminary Injunction (2021-2022)

While the Ohio case (1:22-cv-00280) is the subject of this analysis, the initial legal clash occurred in a related, earlier-filed case in the Northern District of Florida. Rare Breed Triggers first sued Wide Open Enterprises and its distributor, Big Daddy Unlimited, in Florida for patent infringement.

• Complaint Filed (Florida): Rare Breed filed its initial complaint for patent infringement on September 15, 2021, after sending a cease-and-desist letter on August 31, 2021, which the defendants ignored.
• Preliminary Injunction Granted: On 2021-12-30, U.S. District Judge Robert L. Hinkle of the Northern District of Florida granted Rare Breed's motion for a preliminary injunction. The court found that Rare Breed had a high likelihood of success on the merits and would suffer irreparable harm. Judge Hinkle noted that the "Wide Open" trigger was "plainly copied from the FRT-15" and that a monetary judgment might be uncollectible from Wide Open Enterprises, a company seemingly formed solely to sell the accused product. The injunction prohibited the defendants from manufacturing, marketing, or selling the "Wide Open Trigger" or any substantially similar device.
• Ohio Lawsuit Filed: The case in the Northern District of Ohio, 1:22-cv-00280, was filed subsequently. The precise filing date is not clearly available in the search results, but the case number indicates it was the 280th civil case filed in that district in 2022.

Consolidation into Multidistrict Litigation (MDL) (2026)

The most significant procedural development was the consolidation of this and other related patent lawsuits into a single Multidistrict Litigation (MDL) proceeding. This action effectively paused standalone proceedings in the Ohio court.

• MDL Transfer Order: On 2026-04-02, the U.S. Judicial Panel on Multidistrict Litigation (JPML) issued a transfer order consolidating six actions, including the Ohio case, into MDL No. 3176. The panel noted that in addition to the initial six cases, there were 24 other related actions pending in sixteen different districts.
• Transferee Court and Judge: The MDL was transferred to the U.S. District Court for the Eastern District of Texas and assigned to Chief Judge Amos L. Mazzant, III, who is noted to be "well-versed in complex patent litigation."
• MDL Renaming: The JPML renamed the proceeding In re: Rare Breed Triggers Patent Litigation to better reflect the broad scope of cases involving Rare Breed's enforcement of its patents against various alleged infringers, not just those involving a single product type.

Case Posture and Context

The litigation against Wide Open Enterprises is part of a much larger, aggressive patent enforcement campaign by Rare Breed Triggers. This campaign appears to be a direct result of a May 2025 settlement between Rare Breed and the U.S. Department of Justice (DOJ). In that settlement, which favorably resolved the legal status of FRTs by agreeing they are not "machineguns" under federal law, Rare Breed reportedly agreed to actively enforce its patent rights. This enforcement strategy targets numerous alleged infringers in the FRT market.

Parallel PTAB Proceedings

There is no information in the provided search results indicating the existence of any Inter Partes Review (IPR) or other post-grant challenges filed at the Patent Trial and Appeal Board (PTAB) against U.S. Patent No. 10,514,223. The absence of such proceedings suggests that, to date, the validity of the patent has not been challenged through the USPTO's administrative review process.

Current Status and Outcome

As of 2026-05-07, the Ohio case is effectively stayed and is being managed as part of the MDL in the Eastern District of Texas. Key developments will now occur within the consolidated MDL proceedings, including global discovery, claim construction (Markman) hearings, and potentially global settlement discussions or bellwether trials. There has been no final judgment, verdict, or settlement specifically in the Rare Breed v. Wide Open Enterprises case itself; its fate is now tied to the broader MDL.

Plaintiffs' Legal Team in Forced-Reset Trigger Patent Dispute

Plaintiffs RARE BREED TRIGGERS, LLC and its intellectual property holding company, ABC IP, LLC, have assembled a legal team from multiple firms to spearhead their nationwide patent enforcement litigation. While specific roles may evolve now that the case is consolidated into a multidistrict litigation (MDL), the attorneys who filed the initial complaint and have been active in related litigation are identified below.

Lead Counsel

• Marc N. Henschke of Henschke Law, PLLC (Boston, MA)

  • As the founder of a boutique firm specializing in complex litigation, Henschke has over 30 years of experience, with a significant focus on patent infringement cases across various technologies. He is noted as a key attorney in Rare Breed's broader litigation efforts.

• David A. Muser of Muser Rutledge LLP (New York, NY)

  • Muser is an intellectual property litigator whose firm concentrates on patent, trademark, and copyright cases. His involvement underscores the national scope of Rare Breed's legal strategy. Publicly available documents from related proceedings confirm his representation of Rare Breed.

Local Counsel

• Aaron R. Tulencik of Tucker Ellis LLP (Cleveland, OH)
  • Tulencik served as local counsel for the initial filing in the Northern District of Ohio. As a partner in the firm's Intellectual Property department, he brings experience in patent litigation within the district. His signature appears on the original complaint filed in the case.

The composition of this legal team, combining specialized patent litigators with experienced local counsel, is typical for a significant patent enforcement campaign. Following the case's transfer on April 14, 2026, to the Eastern District of Texas for consolidated pretrial proceedings as part of MDL 3176, In re: Rare Breed Triggers Patent Litigation, the court may appoint certain attorneys to leadership roles, such as lead or liaison counsel for all plaintiffs in the consolidated action. However, a specific order appointing MDL leadership for the plaintiffs has not yet been made public. Attorneys who appeared in the original transferor districts are permitted to continue their appearance in the MDL without seeking special admission.

As of today's date, May 7, 2026, publicly available information and court records do not clearly identify the counsel of record for the defendants originally named in the case caption, Wide Open Enterprises LLC and Ottofirearms LLC, under the specified case number 1:22-cv-00280 in the Northern District of Ohio.

Investigation into the docket for this case number reveals a discrepancy with the provided case caption. Court records list the defendants in case 1:22-cv-00280 as Mladen Thomas Strbac (also appearing as Mladen Thomas strbac), Mladen Thomas Strbac doing business as Tommy Triggers, Ram Manufacturing, LLC, and Work Holding Tools, LLC, not Wide Open Enterprises LLC or Ottofirearms LLC.

This particular case, Rare Breed Triggers, LLC et al v. Strbac, was filed on February 21, 2022, and assigned to Judge Solomon Oliver, Jr. However, subsequent searches and review of available docket information have not yielded the names of attorneys who have filed a notice of appearance on behalf of Mladen Thomas Strbac or the other named defendant entities in this specific matter. Filings may be under seal, or an appearance of counsel may not yet be recorded in publicly accessible online databases.

It is noteworthy that in separate, albeit related, patent litigation in the Northern District of Florida, defendant Wide Open Enterprises LLC was represented by counsel from the firm Carlton Fields. This, however, does not confirm their role in the Ohio case.

Therefore, a definitive list of defense counsel for the specific defendants in case 1:22-cv-00280 cannot be provided at this time based on the available information.