Rare Breed Triggers, LLC v. ABC IP, LLC et al.

This patent lawsuit involved a dispute over high-performance firearm triggers between two players in the firearm accessories market. The plaintiff, Rare Breed Triggers, LLC, is an operating company known for manufacturing and selling the FRT-15, a "forced reset trigger" for AR-15 style rifles. These triggers use the energy from the reciprocating bolt carrier group to mechanically reset the trigger, enabling a significantly faster rate of fire compared to standard semi-automatic triggers. The defendants were Brian A. Blakley, an inventor of firearm mechanisms, and ABC IP, LLC, a Delaware-based entity that holds the rights to Blakley's patents. Based on its name and role as the patent assignee, ABC IP, LLC appears to be a patent holding company or non-practicing entity (NPE) for Blakley's inventions.

The lawsuit centered on Rare Breed Triggers' FRT-15 product, which allegedly infringed on the defendants' intellectual property. The specific patent at issue was U.S. Patent No. 7,398,723, titled "Trigger forward displacement system and method." This patent, invented by Blakley, describes a mechanism for a semi-automatic firearm that uses a pivoting cam acted upon by the bolt carrier to actively and positively force the trigger forward into its ready-to-fire position after a shot is fired. The case was filed in the U.S. District Court for the Eastern District of Pennsylvania (2:20-cv-05681), a common venue for patent litigation, though the specific reason for choosing this district is not apparent from publicly available documents. The case was terminated less than three months after it was filed, which is an unusually short duration for patent litigation and may suggest a rapid settlement or a strategic withdrawal, though the specific reason is not detailed in the available information.

This case is notable primarily for its context within the broader, high-stakes legal battle over forced reset triggers. These products have been the subject of intense regulatory scrutiny and litigation involving the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which has argued that such devices are illegal machineguns. Rare Breed Triggers has been a central figure in separate, widely publicized legal challenges against the government's classification of its FRT-15 trigger. This patent infringement suit, therefore, represents a parallel, private dispute over the core technology at the heart of the regulatory controversy, highlighting the competitive and contentious nature of innovation in the firearm accessories market.

Analysis of an Apparent Intracompany Dispute and its Rapid Resolution

Based on available information, the case Rare Breed Triggers, LLC v. ABC IP, LLC et al., No. 2:20-cv-05681, in the Eastern District of Pennsylvania, appears to be an atypical and short-lived legal dispute, likely a declaratory judgment action between a patent licensee and its licensor, rather than a standard patent infringement suit against a third-party competitor. The case was filed on November 13, 2020, and terminated less than three months later on February 10, 2021. The lack of a readily available public docket for this specific case number suggests it was dismissed very early, possibly before any responsive pleadings were filed, and its record may be minimal or sealed.

The defendant, Brian A. Blakley, is the inventor of U.S. Patent No. 7,398,723, titled "Trigger forward displacement system and method." The other defendant, ABC IP, LLC, is the entity that holds the rights to this patent and others invented by Blakley. The plaintiff, Rare Breed Triggers, LLC, is the exclusive licensee and manufacturer of products based on this technology, most notably the FRT-15 "forced reset trigger."

This alignment—the manufacturer/licensee suing the inventor and the IP holding company—is highly unusual. In typical patent litigation, the patent owner and its exclusive licensee are co-plaintiffs enforcing the patent against an alleged infringer. A lawsuit with this posture often indicates an internal dispute over the terms of a license agreement, royalty obligations, or rights to enforce the patent.

Key Developments and Likely Outcome

Given the case's brief duration, it concluded before any significant litigation milestones such as claim construction, substantive motion practice, or trial could have occurred. The most probable developments were as follows:

• Filing of Complaint (2020-11-13): Rare Breed Triggers likely filed a complaint seeking a declaratory judgment to clarify its rights and obligations under its license agreement with ABC IP. The dispute could have concerned the scope of the license, royalty calculations, or which party had the right to sue potential infringers. According to a later government filing in a separate matter, Rare Breed Triggers at one point acquired a patent, assigned it to ABC IP, and then licensed it back, creating a structure where Rare Breed pays royalties to ABC IP. This complex arrangement may have been the subject of the 2020 lawsuit, which could have been filed to formalize or resolve a disagreement over this structure.

• Settlement or Voluntary Dismissal (by 2021-02-10): The termination of the case in under 90 days strongly suggests a prompt, private resolution. The parties likely reached a settlement that clarified their respective rights and obligations, or the plaintiff, Rare Breed, voluntarily dismissed the suit after achieving its strategic objective. This outcome is reinforced by the fact that Rare Breed and ABC IP subsequently began acting in concert.

Subsequent Litigation Confirms Resolution and Partnership

The resolution of any 2020 dispute is evidenced by a wave of later patent litigation where Rare Breed and ABC IP are aligned as co-plaintiffs. Beginning in late 2025, the two companies jointly filed numerous patent infringement lawsuits against competitors, asserting a portfolio of patents including the '723 patent.

Examples of this later, collaborative litigation include:

• ABC IP, LLC and Rare Breed Triggers, Inc. v. Hoffman et al., No. 1:25-cv-00389 (E.D. Tenn.)
• ABC IP, LLC and Rare Breed Triggers, Inc. v. WebCorp, Inc. et al., No. 4:2026cv00018 (E.D. Mo.)
• RARE BREED TRIGGERS, INC. et al v. AS DESIGNS, LLC et al, No. 1:2025cv01192 (M.D.N.C.)

This subsequent pattern of joint enforcement indicates that the 2020 lawsuit served to resolve an internal business conflict, solidifying the relationship between the manufacturer and the intellectual property holding company and paving the way for their unified, aggressive patent enforcement strategy that commenced years later.

Parallel PTAB Proceedings

No parallel IPR or PGR proceedings at the Patent Trial and Appeal Board (PTAB) concerning U.S. Patent No. 7,398,723 during the 2020-2021 timeframe of this specific case have been identified in public records.

Plaintiff's Counsel of Record

Based on available public records, counsel for the plaintiff, Rare Breed Triggers, LLC, in this specific action cannot be definitively identified. The case, filed on November 13, 2020, and terminated on February 10, 2021, was short-lived. Publicly accessible court record databases and legal news archives do not appear to contain notices of appearance for counsel in this matter before its termination.

While Rare Breed Triggers and its associated entity ABC IP, LLC have been represented by various attorneys in other patent litigation across the country, those appearances in different jurisdictions do not confirm who was retained for this specific case in the Eastern District of Pennsylvania.

Therefore, it is likely that no attorneys formally entered an appearance on the public docket before the case was terminated, or the relevant documents are not available through public web searches.

No Counsel of Record Found for Defendants

Despite a thorough search of publicly available records, no counsel of record could be identified for the defendants, ABC IP, LLC and Brian A. Blakley, in case number 2:20-cv-05681 before the Eastern District of Pennsylvania.

The case was filed on November 13, 2020, and terminated less than three months later on February 10, 2021. This unusually short duration suggests the strong possibility that the defendants were never formally served with the complaint or that the plaintiff withdrew the lawsuit before any appearance by defense counsel was required. Without a notice of appearance or any responsive pleadings filed by the defendants, no attorneys were officially recorded on the docket for ABC IP, LLC or Brian A. Blakley in this matter.

Counsel for ABC IP, LLC in Subsequent Litigation

While no attorneys appeared in the specific case at issue, ABC IP, LLC has been an active litigant in other patent enforcement actions, often appearing as a co-plaintiff with Rare Breed Triggers. In these more recent cases, the company has been consistently represented by attorneys from the intellectual property law firm Fish & Richardson P.C.

This information is provided for context but does not confirm representation in the 2020 Pennsylvania case. Notable counsel for ABC IP, LLC in other matters includes:

• Glenn D. Bellamy: Principal at Fish & Richardson's Dallas office. Bellamy is an experienced patent litigator with a focus on complex patent cases.
• Carl E. Bruce: Principal at Fish & Richardson's Dallas office. Bruce has a track record in patent infringement litigation across various technologies.
• Matthew A. Colvin: Principal at Fish & Richardson's Dallas office. Colvin's practice focuses on patent litigation in federal district courts.
• Ben Christoff: Principal at Fish & Richardson's Minneapolis office. Christoff is a patent litigator with experience in a wide range of technical fields.

These attorneys have appeared on behalf of ABC IP, LLC in multiple patent infringement cases filed in 2025 and 2026 across various federal districts, indicating a well-established relationship between the company and the law firm. However, to reiterate, their involvement in the terminated 2020 case cannot be confirmed.