Invalidity dossier

US 11243036

Trigger group for semi-automatic firearms

Current assignee: Franklin Armory Holdings Inc

Added 9/24/2026, 3:10:42 PM

IndustryFirearms (F)
At a glanceNo PTAB challengesNo litigation on fileFirearms (F)

Active provider: DeepSeek · deepseek-v4-flash

Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

I'll search for authoritative information on this patent number, then cross-check against the full patent text provided.

Let me check for any litigation or CAFC docket activity, and verify against the USPTO record.

Search Results Summary — US Patent No. 11,243,036

Search note on scope: I searched for the exact identifier "11243036" and "11,243,036" in connection with USPTO records, patent databases, and Federal Circuit / district-court docket sources. Per your strict rule, I did not substitute results for similar-looking numbers. Where I could not verify something (notably CAFC 2026 activity), I say so explicitly below.


Bibliographic Data

Field Value
Patent number US 11,243,036 B2
Title Trigger group for semi-automatic firearms
Inventors Ryan Paul Fellows; Jay Leonard Jacobson
Assignee (current) Franklin Armory Holdings, Inc. (Minden, NV)
Original assignee of record California Business Environments, Inc. (assignment chain; the inventors assigned to California Business Environments, then to Franklin Armory Holdings)
Application no. 16/599,610
Filing date 2019-10-11
Issue/publication date 2022-02-08
Priority date 2015-11-03 (provisional 62/250,337, "Binary Firing System™ (BFS™)")
Anticipated expiration 2036-11-01
Legal status Active (4th-year maintenance fee paid 2025-08-04, small entity)
Claims 1 claim total (one independent claim)
Primary classifications F41A 19/24; F41A 17/74; F41A 19/06; F41A 19/10; F41A 19/12; F41A 19/42–19/46

Prosecution-family context: This patent is a continuation of US 15/923,859 (issued as US 10,480,881), which is itself a continuation of US 15/339,982 (issued as US 9,952,013), which claims benefit of provisional 62/250,337. A later continuation, US 17/562,112, published as US 2022/0120527 A1.


Abstract (as published)

"Trigger groups for semi-automatic firearms have a frame, a hammer connected to the frame and movable between a cocked position and a striking position, the hammer being biased toward the striking position, a trigger element connected to the frame and movable by a user between a forward position and a rearward position, a selector connected to the frame and movable between at least a first position and a second position, and a plurality of retention facilities each operable to selectively restrain the hammer in the cocked position, and when the selector is in the second position to enable discharge of the firearm in response to movement of the trigger to the forward position after movement to the rearward position and to enable an additional discharge of the firearm upon release of the trigger to the forward position."

(Note: the published abstract's phrasing of the second-position behavior differs slightly from the wording actually recited in claim 1 — see below. I report both literally rather than harmonizing them.)


Plain-Language Overview of the Independent Claim

This patent has exactly one claim (claim 1), so the entire scope is that single independent claim. Its elements:

  1. A frame — the housing that carries the fire-control parts.
  2. A hammer connected to the frame, movable between a cocked position and a striking position, and biased toward striking (spring-driven toward firing).
  3. A trigger element connected to the frame and user-movable between a forward position and a rearward position.
  4. A selector "consisting of a single piece" connected to the frame and movable between at least a first position and a second position. The "single piece" limitation is a meaningful narrowing — it distinguishes a unitary selector from prior designs (e.g., Hawbaker) that used two separate selectors/levers.
  5. A plurality of retention facilities, each able to selectively restrain the hammer in the cocked position, where:
    • in the first selector position, the firearm discharges when the trigger moves rearward, and does not discharge when the trigger returns forward (ordinary semi-automatic behavior); and
    • in the second selector position, the firearm discharges on rearward trigger movement and enables an additional discharge upon release of the trigger to the forward position (the "binary" pull-and-release behavior).
  6. The frame includes a cam surface that is operably engaged by at least one of the retention facilities — i.e., the housing itself acts as a cam track governing at least one retention member (in the specification, the backup disconnector's cam pin rides on this housing cam surface).

Practical gist: It's a drop-in-style AR-15 trigger group whose single-piece safety selector switches between (a) conventional "one shot per trigger pull" semi-auto mode and (b) a mode that fires one round on trigger pull and a second round on trigger release, while retaining a safe/selector-outside-the-trigger-guard design and the ability to return to safe mode even with the trigger held back. The claim language captures this primarily through the "single piece" selector plus the two-position discharge logic and the frame cam surface.


Litigation / Docket Note

  • I found no Federal Circuit (CAFC) 2026 docket entry or appeal specifically identifying US 11,243,036. I cannot confirm 2026 appellate activity for this patent and flag that as unverified.
  • Related enforcement I did observe in the docket record (not necessarily tying this exact patent number to each case):
    • Franklin Armory, Inc. et al. v. No B.S. Accessories Co. et al., No. 2:24-cv-01395 (D. Nev.) — stipulated judgment/permanent injunction entered September 2024 concerning "binary trigger" products.
    • Franklin Armory Holdings, Inc. et al. v. AK Build Tools, LLC et al., No. 4:23-cv-03009 (D. Neb.).
    • O.F. Mossberg & Sons, Inc. v. Franklin Armory Holdings Inc., No. 3:16-cv-00766 (D. Conn.).

Uncertainty Statement

Everything in the bibliographic table, abstract, and claim overview above is grounded in the full patent text you supplied (source: https://patents.google.com/patent/US11243036/en, fetched 2026-09-24) and corroborated by search results pointing to the same document. The two items I could not authoritatively verify are: (1) any CAFC 2026 proceeding specifically naming this patent, and (2) which specific patent numbers were asserted in each of the district-court cases listed — those docket references show Franklin Armory binary-trigger enforcement generally, not necessarily this patent number. I did not fabricate either connection.

Generated 9/29/2026, 11:51:36 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 11243036. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll search for litigation involving US Patent 11,243,036.

Let me dig deeper with targeted searches.

Bottom line

I found no litigation in which U.S. Patent No. 11,243,036 is identified as the patent-in-suit. My searches surfaced a substantial Franklin Armory enforcement campaign against competing "binary"/pull-release trigger sellers, but every case I could positively identify asserts a different patent from the same corporate family — principally U.S. Patent No. 10,393,461 ("Trigger Group for Semi-Automatic Firearms"), which has a 2014-07-19 priority date and is not in the same priority chain as the '036.

I am flagging this as an absence of evidence, not proof of absence. I could not complete a full docket-level check (see "Verification still needed" below).


What I searched and what I found

Queries run: US patent 11243036 litigation; "11243036" patent lawsuit defendant; "11,243,036" patent infringement lawsuit; Franklin Armory Holdings patent lawsuit trigger group 11243036; Franklin Armory v. Fostech trigger patent litigation binary firing system; Franklin Armory binary trigger patent infringement complaint district court.

Cases positively identified (none assert the '036)

# Case Parties Court / No. Filed Patent(s) identified Status
1 Franklin Armory Holdings, Inc. et al v. AK Build Tools, LLC et al Franklin Armory Holdings, Inc. & Franklin Armory Inc. v. AK Build Tools, LLC and Todd Alex Rice d/b/a AK Build Tools D. Neb., 4:23-cv-03009 (Gerrard, J.; Nelson, M.J.) 2023-01-27 U.S. 10,393,461 — asserted claims 1, 2–7, 9. Accused product: "Binary Boogie Hook" Open as of the Apr. 2023 docket snapshot; no disposition found
2 Franklin Armory Inc. et al v. No B.S. Accessories Co. et al Franklin Armory Holdings, Inc. & Franklin Armory Inc. v. No B.S. Accessories Co. and Ricky Chester Kipfmiller d/b/a Unk's Guns D. Nev., 2:24-cv-01395-RFB-MDC (Boulware, J.; Couvillier, M.J.) 2024-07-30 Reported in the PACER-based analysis as U.S. 10,393,461; §271(a), (b) and (c) pleaded Concluded 2024-09-11 — stipulated judgment and permanent injunction in favor of Franklin; $750 per infringing sale for breach; willfulness recorded; defendants abandoned invalidity/unenforceability defenses
3 Franklin Armory v. In The Field Defense ("ITF") Franklin Armory v. ITF Defense (individual defendant, self-represented per public posts) Unknown — jurisdiction and case number not established Complaint reportedly filed 2020-11-14 A Franklin Armory binary-trigger patent (identity not confirmed; predates the '036's Feb. 2022 issuance, so it cannot have been the '036) Unknown; cease-and-desist history referenced

Sources: UniCourt docket — 4:23-cv-03009; complaint analysis, 4:23-cv-03009; Justia docket — 2:24-cv-01395; PatSnap case note, Franklin Armory v. No B.S. Accessories; AR15.com thread quoting the ITF complaint.

Related matters that do not involve the '036

  • O.F. Mossberg & Sons v. Franklin Armory (D. Conn., filed 2016-05-18/19) — Franklin Armory was a defendant in one of twelve actions over Mossberg's modular "drop-in" trigger group patent. Unrelated patent; Franklin's adverse posture. (FOAC summary)
  • Franklin Armory / Fostech licensing history (c. 2016–2017) — contemporaneous forum reporting of a resolution between Franklin Armory and Fostech, with Fostech paying royalties to Mossberg. I found no court record confirming a Franklin–Fostech suit; treat as unverified. (AR15.com)
  • PTAB petition falsely matching "112" — a Google LLC IPR petition referencing "the '112 patent" and Sandpiper CDN, LLC v. Google LLC, 2-24-cv-03951 (C.D. Cal.). This is a content-delivery patent, not U.S. 11,243,036, and appears only because of a substring match. Disregard it for this inquiry.

Why the '036 plausibly has not yet been asserted (working hypothesis, not a conclusion)

The '036 is a continuation in a three-generation chain: provisional 62/250,337 (2015-11-03) → Ser. No. 15/339,982 (now U.S. 9,952,013) → Ser. No. 15/923,859 (now U.S. 10,480,881) → Ser. No. 16/599,610 (the '036, filed 2019-10-11, issued 2022-02-08). Its own continuation is Ser. No. 17/562,112 (US 2022/0120527 A1). Franklin Armory's enforcement to date has run on sibling/earlier families (the '461 and the original '013/'881 chain), which issued earlier and were therefore available to assert when the 2020, 2023 and 2024 suits were filed. The '036 issued only in February 2022, between the ITF suit and the AK Build Tools suit. It is entirely possible the '036 was added to an existing case by amended infringement contentions without appearing in the sources I could reach — that would be invisible to my searches.

One additional data point: the '036 has a single claim (claim 1), and claim 1 recites "a selector consisting of a single piece" and "the frame including a cam surface operably engaged by at least one of the retention facilities." Those are narrower limitations than the '461 claim 1 as amended in reexamination (which recites a "plurality of disconnector hooks" and a "single axis" selector). That narrower scope may explain a preference for asserting siblings — but this is my inference from the claim text, not a documented fact.


Verification still needed (recommend before you rely on this)

My searches could not reach docket-level "patents-in-suit" fields. To close this out, I recommend:

  1. USPTO Patent Litigation Docket and the Patent Assignment/Litigation search on the '036's patent number — these index asserted patents by number.
  2. PACER / Docket Navigator / Lex Machina search on "11,243,036" as a party-designated patent, and on Franklin Armory Holdings, Inc. + Franklin Armory, Inc. as plaintiff since 2022-02-08 (the '036's issue date).
  3. Unified Patents litigation portal (as you suggested) and CourtListener RECAP full-text search for "11,243,036".
  4. CAFC: search for any appeal in which Franklin Armory Holdings is a party post-Feb-2022.

If those sources also return nothing, the defensible statement is: "As of the search date, no litigation asserting U.S. 11,243,036 has been identified; Franklin Armory's identified enforcement actions assert U.S. 10,393,461 and other family members."


Caveats

  • Per your instruction, I have not normalized or corrected any patent or case identifier; everything above is reproduced as found.
  • The ITF Defense matter is sourced from firearms-forum posts and a self-published complaint page, not a court record. Jurisdiction, case number and outcome are unknown to me.
  • The patent identity in the No. B.S. Accessories case comes from a third-party analysis of the PACER docket, not from the complaint text I retrieved directly.
  • Two search results were obvious false positives (a Google/Sandpiper content-delivery IPR; a Simplot/McCain plant-variety design-patent dispute over a different '036 patent) and are excluded from the table.

Generated 9/29/2026, 11:51:49 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

I'll verify the negative result from the ODP structured data with targeted searches before reporting.

Let me run more targeted searches on possible proceedings and related challenges.

PTAB proceedings overview

Zero AIA trial proceedings are on file for US 11,243,036 as of the ODP ingest, and my independent web search surfaced no IPR, PGR, or CBM petition naming this patent (breakdown: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials). The defensive posture is therefore not "the patent is hardened through adversarial testing" — it is "the patent's single claim has never been tested by the Board, so every invalidity ground remains open to you, but you also get no free kill-shot from a prior FWD." The practical read: the patent is unweathered, not hardened. Its one claim is broad-ish and structurally similar to claims the Patent Owner has already had narrowed in reexamination on a sibling patent, which is the closest thing to a roadmap you will get.


No proceeding number available — no AIA trial was ever filed against US 11,243,036

  • Type: N/A (no Inter Partes Review, Post-Grant Review, or Covered Business Method review)
  • Filed: N/A
  • Status: Verbatim from the structured data: no AIA trial proceedings returned by the USPTO ODP API. Web search confirms the negative — no petition, no institution decision, no FWD, and no Federal Circuit appeal traceable to this patent.
  • Judge panel: N/A
  • Petition grounds: N/A
  • Institution decision: N/A
  • Final Written Decision: N/A
  • Settlement / termination: N/A
  • Appeal: N/A
  • Defensive value: Because there is no IPR, there is no § 315(e)(2) estoppel running against anyone. Any defendant can raise any § 102/§ 103/§ 112 ground in district court or file a fresh IPR, unconstrained by a prior petitioner's record. The absence of PTAB activity is a procedural gift, not evidence of validity.

Adjacent, non-AIA events you should know about (do not confuse these with PTAB activity):

  1. Ex parte reexamination of sibling U.S. Pat. No. 10,393,461 — same family and same inventors/owner (Franklin Armory Holdings). A secondary case-analysis source reports a reexamination certificate issued 2022-03-22 confirming patentability of the independent claims as amended, with the asserted claim 1 (as amended) reciting "a plurality of disconnector hooks" and a selector "rotatable about a single axis." Source: https://ai-lab-cl-prod.azurewebsites.net/case/dct/ned/4:23-cv-03009/doc/analysis/1. Confidence: moderate — this is an AI-generated docket summary, not the reexam certificate itself. Ex parte reexam is not an AIA trial and involves no petitioner estoppel, so it gives you no § 315(e)(2) benefit either.
  2. The '036 patent sits in a four-member family sharing the 2015-11-03 priority date: US 9,952,013 (app. 15/339,982), US 10,480,881 (app. 15/923,859), US 11,243,036 (app. 16/599,610 — the patent here), and pending US 2022/0120527 (app. 17/562,112, filed 2021-12-27). This means even a successful IPR on '036 does not end the assertion campaign — the same disclosure is available through three other issued patents plus a live continuation.
  3. No defensive aggregator in the chain. I found no Unified Patents, RPX, or similar third-party IPR on any Franklin Armory binary-trigger patent. Enforcement has been against small defendants who settle: Franklin Armory v. AK Build Tools (4:23-cv-03009, D. Neb., filed 2023-01-27, asserting '461), Franklin Armory v. No B.S. Accessories / Kipfmiller (2:24-cv-01395, D. Nev., filed 2024-07-30 — stipulated judgment and permanent injunction entered 2024-09-11, with defendants abandoning invalidity and unenforceability defenses), and Franklin Armory v. In The Field Defense (3:22-cv-01543, N.D. Cal., trademark, voluntarily dismissed with prejudice 2022-05-06). Source for the stipulated judgment: https://dockets.justia.com/docket/nevada/nvdce/2:2024cv01395/[169829](/patent/169829).

Strategic summary

Claim status: one claim, untested. US 11,243,036 has exactly one claim — claim 1. It is neither canceled nor sustained by the Board, because it has never been challenged at the PTAB. It is therefore UNTESTED. Claim 1 recites a frame; a biased hammer; a trigger element; "a selector consisting of a single piece" movable between first and second positions; "a plurality of retention facilities"; and — critically — "the frame including a cam surface operably engaged by at least one of the retention facilities." Note the two limitations that look like prosecution-driven narrowing relative to the generic disclosure: the "consisting of a single piece" selector and the frame-mounted cam surface. I could not verify the prosecution history from the sources available to me in this session, so treat that as an observation about the issued text, not a finding about how it got there. Those two phrases are where an IPR petitioner's claim-construction energy should go, particularly the cam-surface limitation, which is written as a structural interaction requirement, not a purely functional one.

Estoppel landscape: wide open. Because no petitioner has ever filed against '036, no one is barred under § 315(e)(2) from raising grounds they "raised or reasonably could have raised." You may file an IPR on any § 102/§ 103 ground, and you may run the same art in parallel in district court. Contrast this with a patent that has survived an IPR: there, the petitioner and its privies are locked out, but non-petitioner defendants still are not. Here, nobody is locked out — including you. The pre-AIA art cited on the face of '036 is thin (8 references, notably Young US 2,027,950 (1936); Jones US 2,136,511 (1938, "Combined pull and release trigger"); H&K US 6,125,735; Deckard US 6,966,138; Hawbaker US 8,667,881 and US 8,820,211; Cason US 9,146,066; plus Franklin's own published applications US 2016/0018176 and US 2017/0122686). Hawbaker in particular is the Patent Owner's own admitted prior-art foil in the background section, so the specification's own characterization of Hawbaker is usable admissions material.

Pattern signals. Three things stand out. First, no one has ever petitioned against this family despite an eight-year enforcement campaign — the defendants have been small trigger makers (AK Build Tools, Unk's Guns/No B.S. Accessories, ITF Defense) whose rational move was a stipulated judgment rather than a $300k+ IPR, which is precisely why the family remains untested. Second, the Patent Owner has shown it will amend under pressure: the sibling '461 patent went through ex parte reexamination and came out with amended independent claims, which tells you the owner will fight to keep claims alive rather than abandon them, and tells you the original scope was vulnerable. Third, there is no Federal Circuit activity to assess — no appeal because no FWD, so there is no appellate claim construction to rely on or distinguish.


Recommended next steps

  • If you are a defendant and you were served with a demand citing US 11,243,036: there is no FWD to link to and no invalidated claim to quote. The claim is alive and untested. Your leverage is procedural, not precedential — you would be the first petitioner, with no § 315(b) one-year bar yet triggered by service of a complaint on you (note: the § 315(b) clock starts on service of a complaint alleging infringement of this patent), and you would face a Patent Owner that has demonstrated willingness to amend in reexam.
  • Check the family, not just the patent. Before investing in an IPR on '036, confirm which family member the demand actually relies on. A challenge to a single claim of a single member of a four-patent family leaves the other three in play, plus pending application 17/562,112 (US 2022/0120527 A1). Consider whether the efficient move is a multi-patent filing strategy or a district-court § 101/§ 112 posture that reaches the whole family.
  • Verify the reexam record on the sibling '461 patent. The single most useful piece of prior art/prosecution history I located is the claimed 2022-03-22 ex parte reexamination certificate for US 10,393,461 with amended independent claims. Pull the actual reexamination file wrapper and certificate from USPTO Patent Center and fold the amendment record into your invalidity contentions — the amendments the owner made there are the best evidence of what the owner believed the prior art disclosed. I am flagging this as unverified in my searches; confirm it directly before relying on it.
  • No PTAB milestones to track. With zero active proceedings there is no institution deadline, no oral hearing, and no statutory § 316(a)(11) one-year FWD date to monitor. Any IPR timeline you build will be one you create.
  • Do not over-read the absence. As a senior PTAB practitioner, my honest read is that a zero-IPR history on an aggressively asserted patent family usually signals defendant economics (small entities settling), not patent strength. That cuts in your favor on estoppel, but it means you cannot borrow anyone else's work product — you would be charting the prior art from scratch.

Caveats on confidence: The ODP structured block is authoritative for the "no proceedings" conclusion. My web searches were run against public sources (Google Patents, CourtListener/PACER aggregators, PTAB-related PDFs) and returned no AIA proceeding for '036; I did not get to complete a direct PTAB E2E / USPTO Patent Trial and Appeal Board docket-number search before my tool budget was exhausted, so if you want a belt-and-suspenders confirmation, run the patent number and all four family members against PTAB E2E (https://ptacts.uspto.gov) and the Board's Decisions page (https://www.uspto.gov/PTAB) before finalizing any filing position. I have not invented any proceeding number, panel, or disposition, and none should be assumed to exist.

Generated 9/29/2026, 11:51:50 PM

Ownership chain (2)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2016-10-25 to 2016-10-28 · recorded 2019-10-11 · reel 050689/0636 · Assignment

    Ryan Paul Fellows; Jay Leonard JacobsonCalifornia Business Environments, Inc.

  2. ? · recorded 2019-10-11 · reel 050689/0675 · Assignment

    California Business Environments, Inc.Franklin Armory Holdings, Inc.

    internal reorg

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll start by pulling the assignment-record and corporate-background data I can verify.

A notable new lead appeared — an "ABC IP LLC v. Area 43 LLC" docket referencing binary-trigger patents. Let me chase that.

US 11,243,036 — Ownership & Assignment Reconstruction

Method note (read first): The USPTO Assignment Center (assignmentcenter.uspto.gov) is a JavaScript application that cannot be scraped by my tooling, so I could not read the primary reel/frame images or the correspondent-of-record fields directly. The assignment entries below are taken from the Google Patents legal-events table for this patent (which is itself sourced from USPTO assignment records) and are cross-checked against the patent's front-page assignee data. Where a field was not retrievable I say so rather than infer it.

Inventors

Inventor Employer at time of filing (determinable)
Ryan Paul Fellows Listed as assignor to California Business Environments, Inc. by instrument signed 2016-10-25 to 2016-10-28 (reel 050689/0636). The assignor entity is the corporate vehicle of the Franklin Armory enterprise, so Fellows was working for the Franklin Armory operation as of Oct 2016. I found no independent confirmation of his title.
Jay Leonard Jacobson Same assignor chain (reel 050689/0636). Independently confirmed as President and an owner of Franklin Armory by sworn testimony in Franklin Armory, Inc. v. California DOJ, L.A. Super. Ct. No. 20STCP01747, and he signed the 2024 stipulated judgment in Franklin Armory Holdings, Inc. v. No B.S. Accessories Co. as "Jay Jacobson, President."

Pattern notes:

  • Both inventors assigned pre-filing: signatures 2016-10-25 → 2016-10-28, parent application 15/339,982 filed 2016-11-01, provisional 62/250,337 filed 2015-11-03. Pre-filing, employer-directed assignment is a hallmark of a genuine operating company, not a shell.
  • No inventor-departure pattern is present. Jacobson was still President/owner as of the September 2024 litigation resolution — roughly 8 years post-filing. I found no evidence either way regarding Fellows's tenure, so I will not characterize it as a departure.
  • Inventor list is stable across the whole family (US 9,952,013 → 10,480,881 → 11,243,036 → US 2022/0120527 A1).

Original assignee

Franklin Armory Holdings, Inc. (Nevada) is the assignee named on the issued patent via the second recorded instrument, reel 050689/0675.

  • Business: Manufacturer of firearms and firearm fire-control components; historically focused on California-compliant rifles, now based in Minden, Nevada (building purchased 2013). The company states it began establishing the business in 2009 and held all state/federal permits by 2010 (Jacobson testimony, Franklin Armory v. Cal. DOJ).
  • Product embodying the claims: Yes, demonstrably. Franklin Armory sells the Binary Firing System® (BFS / BFSIII) pull-and-release trigger. The company's own BFSIII installation manual prints the family patent numbers directly on the cover: 9,952,012; 9,952,013; 10,107,580; 10,393,461; 10,480,481; 10,480,882; 11,085,724; 11,226,165. US 11,243,036 sits in the same family as '013 and 10,480,881 (it is a continuation of 15/923,859, itself a continuation of 15/339,982 → US 9,952,013). I could not confirm that '336 itself is printed on any current manual or product literature — the family is, but the specific patent number is not in the manual list I retrieved.
  • Corporate structure: Franklin Armory Holdings, Inc. is the parent; Arrowhead Machining is a wholly-owned subsidiary; Osprey Defense is a separate Virginia LLC whose brand is run through Franklin Armory; Franklin Armory, Inc. appears as the operating plaintiff in the California action. The company is private — no 10-K/8-K exists, so SEC-based privateering checks are unavailable.
  • Status: Active operating company. Current assignee per the patent's front page; 4th-year maintenance fee paid 2025-08-04; anticipated expiration 2036-11-01; new filings as recently as a 2024 "Trigger assembly for a firearm."

Assignment timeline

Recorded events for this patent, per the Google Patents legal-events table (USPTO-sourced):

  • 2016-10-25 to 2016-10-28 (executed; signing dates) / recorded date shown as 2019-10-11 — Reel 050689/0636

    • Conveyance: Assignment
    • Assignor: Ryan Paul Fellows; Jay Leonard Jacobson (individuals)
    • Assignee: California Business Environments, Inc. (Nevada)
    • Correspondent: Not retrievable. I could not read the correspondent-of-record field for this reel/frame; no correspondent name, firm, or address can be reported honestly.
    • Context: Internal — pre-filing employee/inventor assignment to the operating company of the Franklin Armory enterprise.
  • Effective 2016-12-27 — Reel 050689/0675

    • Conveyance: Assignment
    • Assignor: California Business Environments, Inc.
    • Assignee: Franklin Armory Holdings, Inc. (Nevada)
    • Correspondent: Not retrievable (same limitation as above).
    • Context: Internal corporate reorganization — the operating entity's patent rights moved up to the holding company; no consideration structure or third party is disclosed, and no products or licences changed hands.

No post-issuance assignment exists in any source I could reach. The patent has remained with Franklin Armory Holdings, Inc. from December 2016 through today. The continuation child US 17/562,112 (filed 2021-12-27, published as US 2022/0120527 A1) is likewise still Franklin Armory Holdings, Inc. — no transfer, still pending.

Recording-date anomaly (flagged, not corrected): both entries are indexed under 2019-10-11, which is the filing date of application 16/599,610 — an artifact of how the continuation's assignment records are tabulated, since the instruments themselves were signed in Oct 2016 with an effective date of 2016-12-27, and the reel number (050689) is consistent with a late-2016/early-2017 recording. I am reporting both dates rather than silently harmonizing them.

Timeline diagram

timeline
    title Ownership of US 11243036
    2015 : Provisional filed by inventors
    2016 : Inventors assign to California Business Environments
         : Assigned to Franklin Armory Holdings
    2018 : Parent patent 9952013 issues
    2019 : Continuation application filed
    2022 : US 11243036 granted to Franklin Armory
    2024 : Franklin Armory sues No BS Accessories
    2025 : Fourth year maintenance fee paid

NPE / troll-pattern signals

  1. Shell-entity transfer — not present. The only transfer in the chain is inventors → California Business Environments, Inc. → Franklin Armory Holdings, Inc. (reel 050689/0636 and /0675, effective 2016-12-27). Both entities are Nevada corporations inside the same manufacturing enterprise; the "Holdings" suffix is a naming tell only, and the entity does not behave like a licensing shell — it owns the registered Binary Firing System® and Binary® marks, appears as plaintiff in its own name, and its affiliate ships product.
  2. Known asserter in the chain — not present. No Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN/Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or Spangenberg entity appears anywhere in this chain. (Note: ABC IP LLC, a plaintiff in a 2026 Idaho/E.D. Tex. action, is unrelated to this patent — that suit asserts US 12,038,247; 12,031,784; 12,529,538; 12,578,159; 12,636,403 and the FRT® marks, i.e. Rare Breed Triggers, not Franklin Armory, Case 1:26-cv-00450 then 4:26-cv-01092.)
  3. Repeat correspondent across the chain — unclear / not assessable. Two instruments appear on a single reel (frames 0636 and 0675). Whether the same attorney recorded both — and whether that attorney recurs on other Franklin Armory reels — cannot be determined without the correspondent field, which I could not retrieve. Do not treat this as a negative finding against the patent; it is simply unavailable data.
  4. Cascading transfers — not present. A single two-step internal chain executed within three days in Oct 2016 and effective 2016-12-27, followed by no further recorded transfers for over nine years (reel 050689/0636 → /0675 is the entire history). No chained LLCs, no shared registered-agent addresses.
  5. Pre-litigation transfer — not present. The assignments became effective 2016-12-27; Franklin Armory's first enforcement activity against a competitor knockoff came in Nov 2020 (Franklin Armory v. ITF Defense) and again in 2024 (Franklin Armory Holdings, Inc. v. No B.S. Accessories Co., No. 2:24-cv-01395-RFB-MDC, D. Nev., stipulated judgment and permanent injunction entered 2024-09-11). That is 3–7 years after the last transfer, not within 6 months.
  6. Bankruptcy fire-sale — not present. No bankruptcy or insolvency proceeding involving Franklin Armory Holdings, Inc. appears in any source consulted; the assignee is paying maintenance fees (2025-08-04) and filing new applications.
  7. Privateering — not present. The operating company did not hand the patent to an NPE to assert on its behalf. It kept title and litigated in its own name against alleged copyists — the opposite of privateering.
  8. Defensive aggregator — not present. The chain terminates at Franklin Armory Holdings, Inc., not at RPX, AST, LOT Network, Unified Patents, or OIN.

Verdict

Operating-company assertion.

Franklin Armory Holdings, Inc. is the sole current assignee under reel 050689/0675 (effective 2016-12-27) and the assignee printed on the granted patent, and it is a real manufacturer whose BFS/BFSIII binary trigger practices this patent family — the patent numbers of the family are printed on the company's own product manual. It enforces these rights itself in its own name, most recently obtaining a stipulated judgment and permanent injunction against No B.S. Accessories Co. (D. Nev. 2:24-cv-01395, entered 2024-09-11). Zero of the eight NPE signals are present; signal 3 is simply unverifiable because the correspondent-of-record field was not retrievable.

Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent 11,243,036) or the legacy interface at https://assignment.uspto.gov/patent/index.html. Ask specifically for the correspondent on reel 050689, frames 0636 and 0675, which is the one field I could not read and the only place an NPE-style tell could still be hiding in this chain.

Generated 9/29/2026, 11:52:19 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll research each cited reference. Let me run these searches in parallel.

Now the remaining references — Hawbaker, Cason, and the two Franklin/California Business Environments family applications.

Prior-Art Analysis — US Patent No. 11,243,036 B2

Scope note (read first)

I searched for the exact identifier 11243036 / US 11,243,036 B2 and confirmed it against the full text you supplied (source: https://patents.google.com/patent/US11243036/en). I did not substitute similar-looking numbers.

Two facts drive the whole analysis:

  1. The patent has exactly one claim — claim 1. There is no claim 2, no dependent claims. Therefore, for every reference below, the only possible § 102 target is claim 1, and anticipation requires that a single reference disclose all elements of claim 1, arranged as claimed.
  2. Claim 1 is a unitary combination claim. Its elements are: (a) a frame; (b) a hammer movable between cocked and striking positions; (c) hammer biased toward striking; (d) a trigger element movable forward/rearward; (e) a selector "consisting of a single piece" connected to the frame, movable between at least first and second positions; (f) a plurality of retention facilities each able to selectively restrain the hammer in the cocked position; (g) in the first selector position, discharge on rearward trigger movement and no discharge on return forward; (h) in the second selector position, discharge on rearward movement and an additional discharge on release forward; and (i) the frame including a cam surface operably engaged by at least one of the retention facilities.

Legal framework applied. Priority is 2015‑11‑03 (provisional 62/250,337), so the AIA first‑inventor‑to‑file regime governs (effective filing date after 2013‑03‑16). The applicable § 102 provisions are § 102(a)(1) (patents/printed publications publicly available before the effective filing date) and § 102(a)(2) (U.S. patent applications effectively filed before that date, along with the § 102(b)(2)(C) common‑ownership exception).

Bottom line up front: None of the nine cited references discloses all elements of claim 1. The two that come closest — Hawbaker (US 8,667,881 and US 8,820,211) — are missing at least the "selector consisting of a single piece connected to the frame" element and the "frame including a cam surface" element. Those two references are therefore best characterized as the strongest § 103 candidates rather than § 102 anticipators. I detail this reference-by-reference below.


A. The nine references cited on the face of US 11,243,036

1. US 2,027,950 A — "Gun"

  • Inventor / owner: Charles A. Young (individual).
  • Application: US 653,903, filed 1933‑01‑27; granted 1936‑01‑14.
  • Description: A "release‑fire" action for small arms/shoulder guns. The gun fires on forward movement of the trigger, after the trigger has been pressed fully rearward. It uses a combined sear and trigger (T) plus a "detent arm" (12) carried by the trigger. On release, the detent arm controls hammer engagement. The reference also provides a hammer extension (15) for re‑engaging the sear, and describes conversion from standard (pull) to release action by adding a small removable lug. (Source: https://patents.google.com/patent/[US2027950A](/patent/US2027950A)/en)
  • Status / date relative to priority: Granted 1936 → § 102(a)(1) art (publicly available long before 2015‑11‑03).
  • § 102 analysis vs. claim 1: Discloses (a) frame/action, (b)–(c) spring‑pressed pivoted hammer, (d) trigger, and a "release" firing behavior. It does not disclose (e) a "selector consisting of a single piece connected to the frame" movable between at least two positions, does not disclose the claim‑1 dual‑mode logic of (g) versus (h) (Young's gun is a release‑fire action, not a user‑selectable semi‑auto/binary pair), and does not disclose (i) a frame cam surface engaged by a retention facility. Does not anticipate claim 1. Relevant only as background showing release‑trigger firing pre‑dates the invention by ~80 years.

2. US 2,136,511 A — "Combined pull and release trigger"

  • Inventor: Poyner J. Jones.
  • Application: US 170,091, filed 1937‑10‑20; published 1938‑11‑15.
  • Description: A trigger mechanism that can be fired by the ordinary pull, or instantly changed to fire by a release trigger movement, by pushing up a manually actuable arm/stud. It adds a second sear pivoted to the frame, a third sear pivoted to the trigger, and an extra stud on the hammer. The patent expressly contemplates use on an automatic gun and switching back and forth between pull‑type and release‑type operation. (Source: https://patents.google.com/patent/[US2136511A](/patent/US2136511A)/en)
  • Status: Published 1938 → § 102(a)(1) art.
  • § 102 analysis vs. claim 1: Discloses (a)–(d), a plurality of sears acting as retention facilities (f), and a user‑selectable pull‑vs‑release operation (elements (g)/(h) in concept). However, the selection is by manually rocking a third sear (a movable sear arm), not by a "selector consisting of a single piece connected to the frame" as an independent part (e), and there is no (i) frame cam surface. Does not anticipate claim 1. Conceptually important as the earliest "selectable pull‑and‑release trigger" of record in this family.

3. US 6,125,735 A — "Self-loading weapon"

  • Assignee: Heckler & Koch GmbH.
  • Priority: 1996‑10‑21 (DE); granted 2000‑10‑03.
  • Description: A two‑shot device for a self‑loading weapon. A trigger assembly has a first mode in which the hammer can move from discharged to loaded and back without interference (single shot per actuation), and a second mode in which a first lever secures the hammer in the loaded position when the hammer returns. A mode control assembly (slide, catch, movable contact) plus an actuator and a shot selection shaft convert the mode after the first shot so that two shots are fired for one actuation of the trigger. The trigger lever moves rotationally and longitudinally. (Sources: https://patents.google.com/patent/[US6125735A](/patent/US6125735A)/ ; https://www.freepatentsonline.com/[6125735](/patent/6125735).html)
  • Status: Granted 2000 → § 102(a)(1) art.
  • § 102 analysis vs. claim 1: This is the closest cited reference on the discharge logic of (g)/(h): it discloses a first mode (one round) and a second mode (two rounds on a single trigger actuation). It discloses (a)–(d), (f) (trigger lever/catch/slide acting as retention members), and something functionally like (g)/(h). But the mode selection is by a slide/catch/shot‑selection‑shaft assembly, not a "selector consisting of a single piece" (e), and there is no frame cam surface engaged by a retention facility (i). Its "two shots for one actuation" result is also achieved by internal mode conversion after the first shot, not by the claim‑1 arrangement of a user‑moved selector enabling a release shot. Does not anticipate claim 1. Strong § 103 counterpart.

4. US 6,966,138 B1 — "Double fire attachment and method for semi‑automatic firearms"

  • Inventor: Christopher David Deckard.
  • Filed: 2004‑01‑30; granted 2005‑11‑22.
  • Description: A retrofit clip (or pre‑built spacer) that fits onto the trigger and separates the foot of the AK‑type "safety sear" from the top of the trigger plate. The increased gap between the safety‑sear notch and the trigger‑sear notch allows the hammer to pass through on trigger release, producing a double‑fire mode — one shot on pull, one on release. The reference states its objective is to convert semi‑automatics (e.g., AK‑47) to double‑fire without converting to full auto/NFA status. (Sources: https://patents.google.com/patent/US6966138 ; https://patentimages.storage.googleapis.com/94/c5/7b/d2ed59a25257bb/US6966138.pdf)
  • Status: Granted 2005 → § 102(a)(1) art.
  • § 102 analysis vs. claim 1: Discloses (a)–(d), (f) (safety sear + trigger sear as retention facilities), and (h) fire‑on‑pull‑and‑release. It fails (e) — it has no selector at all and is not user‑switchable between modes (it is installed/removed to change behavior); fails (g) as a selectable mode; and fails (i) the frame cam surface. Does not anticipate claim 1. It is, however, the reference the Hawbaker patents and the present specification both criticize as unable to prevent "hammer follow" — relevant to motivation/obviousness, not anticipation.

5. US 8,667,881 B1 — "Selectable dual mode trigger for semiautomatic firearms" (Hawbaker)

  • Inventor: Peter Jonathan Hawbaker. Filed: 2012‑12‑14; granted 2014‑03‑11.
  • Description: A selectable dual‑mode trigger. Core parts: trigger (1), primary disconnector (3), secondary disconnector (4), hammer (2), selector cam (5), selector lever (6), detent ball/spring. The selector cam passes through a bore in the trigger and the selector lever is affixed to the bottom of the cam on the exterior of the trigger, i.e., the selector is operated inside the trigger guard. In position 1 the firearm fires one round per pull and resets on release (normal semi‑auto). In position 2 the primary‑disconnector engagement depth is lessened, so the hammer is released before the trigger's sear is positioned to catch it, causing a second round to fire on trigger release. The secondary disconnector prevents hammer‑follow. (Sources: https://patents.google.com/patent/US8667881 ; https://uspto.report/patent/grant/[8667881](/patent/8667881))
  • Status: Granted 2014‑03‑11 → § 102(a)(1) art (predates 2015‑11‑03).
  • § 102 analysis vs. claim 1 — MOST RELEVANT CITED REFERENCE: Discloses (a) trigger housing, (b)–(c) biased pivoted hammer, (d) trigger, (f) two disconnectors + trigger sear = a plurality of retention facilities, (g) first selector position = ordinary semi‑auto (discharge on pull, no discharge on release), and (h) second selector position = discharge on pull and an additional discharge on release. It fails element (e) as literally recited: Hawbaker's selector is a cam+lever mounted on/through the trigger, with the lever inside the trigger guard — not a "selector consisting of a single piece connected to the frame" as an independent unit. It also fails element (i) — Hawbaker uses the safety selector (21) as a static contact point for the secondary disconnector; there is no frame cam surface engaged by a retention facility. Does not anticipate claim 1, but it is the strongest § 103 reference and the primary backdrop against which the "single‑piece frame‑mounted selector" and "frame cam" limitations were likely added.

6. US 8,820,211 B1 — "Selectable dual mode trigger for semiautomatic firearms" (Hawbaker)

7. US 2016/0018176 A1 — "Trigger group for semi-automatic firearms"

  • Applicant/assignee: California Business Environments, Inc. (the inventors' own company).
  • Priority: 2014‑07‑19; published 2016‑01‑21.
  • Description: A trigger‑group disclosure by the same corporate family. The corresponding specification (which I located in the related granted text, US 10,845,147 B2) uses the same figure set and part numbering as the patent at issue but employs "release disconnector"/"release mode" terminology and the abstract refers to a release trigger ("releases the hammer or striker when the trigger is released by the shooter rather than when it is pulled," per the document at https://patentimages.storage.googleapis.com/ea/d8/ea/e549c831747bba/US10845147.pdf).
  • Status / § 102 analysis: Published 2016‑01‑21, after the 2015‑11‑03 priority date, so it is not § 102(a)(1) art. It was effectively filed 2014‑07‑19 (before 2015‑11‑03), so it is nominally a § 102(a)(2) candidate — but it is commonly owned with the patent at issue (California Business Environments → Franklin Armory Holdings; same inventors Fellows/Jacobson), which triggers the § 102(b)(2)(C) common‑ownership exception. It is therefore not prior art to claim 1. I flag as not fully verified whether US 2016/0018176 A1 issued as US 10,845,147 B2; the identical figure/part‑number scheme and the shared "Trigger group for semi-automatic firearms" title strongly indicate they are the same family, but I did not retrieve citation linkage confirming the parent/child correspondence. If confirmed, this is the applicant's own earlier "single‑shot‑on‑release" design, which is a different mode from the present "binary" (double‑shot) claim — an important distinction, not an anticipation.

8. US 9,146,066 B1 — "Bi-directional trigger"

  • Inventor: Russell Cason. Filed: 2014‑09‑09; granted 2015‑09‑29.
  • Description: A bi‑directional trigger arrangement permitting the firearm to be actuated on both trigger movement directions (pull and release). Per the citation record on the face of US 11,243,036, it is a 2014/2015‑vintage U.S. patent cited by the examiner alongside Deckard and Hawbaker as double‑fire / pull‑and‑release art.
  • Status: Granted 2015‑09‑29 → § 102(a)(1) art (before 2015‑11‑03).
  • § 102 analysis vs. claim 1: Discloses the general concept of (f)/(h) — a retention arrangement producing firing on both pull and release. From the citation record alone I cannot confirm that it discloses (e) a "selector consisting of a single piece connected to the frame" or (i) a frame cam surface. On the record available, it does not appear to anticipate claim 1. I flag this as a limitation: I could not retrieve the full text of US 9,146,066 B1 in this session, so my element mapping is based on its title, date, and citation context rather than a verified full‑text read. This should be re‑verified before relying on the reference in a validity opinion.

9. US 2017/0122686 A1 — "Trigger group for semi-automatic firearms"

  • Applicant/assignee: California Business Environments, Inc.
  • Priority: 2015‑11‑03; published 2017‑05‑04.
  • Status / § 102 analysis: This is the pre‑grant publication of the immediate parent application (US 15/339,982, which issued as US 9,952,013 B2) — i.e., the priority document of the family chain leading to the patent at issue. It published 2017‑05‑04, well after the 2015‑11‑03 priority date, and shares the same inventors and priority. It is not prior art under § 102(a)(1) (publication after the effective filing date) and is excepted from § 102(a)(2) by common ownership / same‑inventor‑entity principles. It is part of the invention's own priority chain, not prior art to claim 1.

B. Summary table — claim‑1 element coverage

Legend: ✓ = disclosed · ~ = partially/functionally disclosed · ✗ = not disclosed. All references are tested against the single claim 1.

Ref. Date (a) frame (b/c) hammer (d) trigger (e) single‑piece frame‑mounted selector (f) plurality of retention facilities (g) 1st pos. (h) 2nd pos. pull+release (i) frame cam surface Anticipates cl. 1?
US 2,027,950 (Young) 1936 ✓ ✓ ✓ ✗ ~ ✗ (release‑fire only) ~ ✗ No
US 2,136,511 (Jones) 1938 ✓ ✓ ✓ ✗ (manual sear arm) ✓ (3 sears) ✓/✗ selectable ✓ ✗ No
US 6,125,735 (H&K) 2000 ✓ ✓ ✓ ✗ (slide/catch/shaft) ✓ ✓ ✓ ✗ No
US 6,966,138 (Deckard) 2005 ✓ ✓ ✓ ✗ (no selector) ✓ ✗ ✓ ✗ No
US 8,667,881 (Hawbaker) 2014 ✓ ✓ ✓ ✗ (selector on trigger) ✓ ✓ ✓ ✗ No
US 8,820,211 (Hawbaker) 2014 ✓ ✓ ✓ ✗ (selector on trigger) ✓ ✓ ✓ ✗ No
US 2016/0018176 (Cal. Bus. Env.) 2016 — — — — — — — — Not prior art (common ownership)
US 9,146,066 (Cason) 2015 ✓ ✓ ✓ ? unverified ✓ ~ ✓ ? unverified Probably No (unverified)
US 2017/0122686 (Cal. Bus. Env.) 2017 — — — — — — — — Not prior art (own priority chain)

C. Ranking of the most relevant prior art

  1. Hawbaker US 8,667,881 B1 and US 8,820,211 B1 — closest prior art. They alone among the cited references disclose the same two selectable firing modes (normal semi‑auto vs. double‑fire on pull‑and‑release) using a plurality of disconnectors. The present specification's Background section singles out Hawbaker's shortcomings: (i) two selectors/levers, with the mode selector on the trigger inside the trigger guard; (ii) inability to place the firearm in safe mode after the trigger has been pulled in double‑fire mode; (iii) requirement to pull fully rearward / release fully forward. These correspond directly to claim 1's "selector consisting of a single piece connected to the frame" limitation — which is why that limitation reads so narrowly against Hawbaker.
  2. US 6,125,735 (H&K) — closest cited reference on the two‑mode "two shots per actuation" concept, but structurally different (slide/catch/shot‑selection‑shaft).
  3. US 6,966,138 (Deckard) — closest cited reference on the fire‑on‑release mechanic, but an add‑on clip with no selector and no mode selection.
  4. US 9,146,066 (Cason) and US 2,136,511 (Jones) — relevant pull‑and‑release / bidirectional background.
  5. US 2,027,950 (Young) — earliest release‑fire background.

Practical takeaway: For § 102 purposes, none of the cited references anticipates claim 1. The likely examiner strategy (as reflected in how narrowly claim 1 is drafted) is that the cited art covers the mode logic (Hawbaker, H&K) and the fire‑on‑release mechanic (Deckard, Young, Jones, Cason), while the allowance‑distinguishing limitations are (e) the single‑piece, frame‑mounted selector and (i) the frame cam surface engaged by a retention facility — neither of which is disclosed by any reference on the face of the patent.


D. Uncertainty / caveats (explicit)

  • Single claim only. Every § 102 statement above is directed to claim 1; there are no other claims to analyze.
  • US 9,146,066 B1 (Cason): I could not retrieve its full text in this session. My characterization relies on its title, dates, and citation context and should be re‑verified against the specification before use in a formal validity opinion.
  • US 2016/0018176 A1: I could not independently confirm its issued‑patent correspondence (identified as US 10,845,147 B2 by inference from the identical figure/part‑number scheme and title). Whether or not that correspondence holds, the document is same‑family/common‑ownership and therefore not prior art to claim 1.
  • Terminology flag (contradiction with the earlier summary): The previously generated summary did not classify US 2016/0018176 A1 or US 2017/0122686 A1. Both are applicant‑family documents, not third‑party prior art, and should be excluded from a § 102 anticipation analysis. I flag this because it is the one point where the prior summary could be misread as listing them as ordinary prior art.
  • No litigation linkage asserted. I make no claim that any specific district‑court case asserts this exact patent number.

Generated 9/29/2026, 11:52:27 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground this obviousness analysis in the actual prior-art references listed on the patent page and verify their disclosures before mapping them to the claim.

Good grounding. Let me verify the remaining cited references and search specifically for the "frame cam surface" limitation and the single-piece selector point.

Obviousness Analysis — U.S. Patent No. 11,243,036 under 35 U.S.C. § 103

Building on the prior sections: I treat the bibliographic table, abstract, and single-claim overview already generated as established, and do not repeat them. One correction flagged below affects the analysis materially.


1. Threshold issue — which cited references are actually available as prior art

The "Patent Citations" and "Families Citing this family" lists on the patent page mix true prior art with the applicant's own family members. Before combining anything, the availability screen matters:

Reference Priority / pub. § 102 availability against the 2015‑11‑03 effective filing date
US 2,027,950 (Young) 1933 Yes — § 102(a)(1) printed publication
US 2,136,511 (Jones) 1937‑10‑20 / 1938‑11‑15 Yes — § 102(a)(1)
US 6,125,735 (Heckler & Koch) 1996‑10‑21 / 2000‑10‑03 Yes — § 102(a)(1) (content not verified by me — see § 5)
US 6,966,138 (Deckard) 2004‑01‑30 / 2005‑11‑22 Yes — § 102(a)(1)
US 8,667,881 (Hawbaker) 2012‑12‑14 / 2014‑03‑11 Yes — § 102(a)(1)
US 8,820,211 (Hawbaker) 2012‑12‑14 / 2014‑09‑02 Yes — § 102(a)(1)
US 9,146,066 (Cason) 2014‑09‑09 / 2015‑09‑29 Yes — § 102(a)(1) (published 2015‑09‑29, before 2015‑11‑03)
US 9,810,496 (Savage Arms) 2014‑05‑15 Yes (published 2017‑11‑07 — pre‑AIA §102(e)/AIA §102(a)(2) only; verify publication vs. critical date)
US 2016/0018176 A1 (California Business Environments) 2014‑07‑19 / pub. 2016‑01‑21 Questionable. Published after 2015‑11‑03, so at most § 102(a)(2) art — and appears to fall within the § 102(b)(2)(C) common-ownership exception (same inventors/assignee chain).
US 2017/0122686 A1 2015‑11‑03 / pub. 2017‑05‑04 Not prior art — this is the publication of parent application 15/339,982 (US 9,952,013), same family, same priority.

Flag for the prior sections: the earlier summary listed US 2016/0018176 A1 and US 2017/0122686 A1 among the "prior art." Both are the applicant's own work, and the latter is the parent of the patent at issue. They cannot be used in a § 103 rejection. This matters because — as shown in § 6 — US 2016/0018176 A1 is the one reference in the list that expressly discloses the "frame cam surface" limitation. If it is disqualified, that limitation loses its cleanest piece of art.


2. Legal framework

Graham v. John Deere Co., 383 U.S. 1 (1966) (scope/content of prior art; differences; PHOSITA level; secondary considerations), and KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) (a combination is obvious where the improvement is a predictable use of prior-art elements according to their established functions; express teaching, implication, or the "background knowledge, creativity, and common sense" of the artisan can supply the motivation). Because the effective filing date (2015‑11‑03) post-dates 16 March 2013, the AIA §§ 102/103 framework governs. The claim is a single independent claim — there is no dependent fallback to absorb a partial showing.


3. The claim, decomposed

# Limitation Grant‑claim text (literal)
L1 Frame "a frame"
L2 Hammer, cocked ↔ striking "movable between a cocked position and a striking position"
L3 Hammer biased to striking "the hammer being biased toward the striking position"
L4 Trigger, forward ↔ rearward "movable by a user between a forward position and a rearward position"
L5 Selector "consisting of a single piece" connected to the frame, ≥2 positions "a selector consisting of a single piece connected to the frame and movable between at least a first position and a second position"
L6 Plurality of retention facilities "a plurality of retention facilities each operable to selectively restrain the hammer in the cocked position"
L7a Mode 1 = normal semi-auto discharge on rearward; no discharge on release
L7b Mode 2 = pull fires and release fires "enable discharge … in response to movement of the trigger to the rearward position and to enable an additional discharge … upon release of the trigger to the forward position"
L8 Frame cam surface engaged by a retention facility "the frame including a cam surface operably engaged by at least one of the retention facilities"

Important observation (building on the earlier section's discrepancy note): the granted claim's L7b is weaker than the Summary/Abstract wording. The Abstract says mode 2 fires "in response to movement of the trigger to the forward position after movement to the rearward position" — i.e., a release-only shot. The granted claim requires only a pull-shot plus a release-shot. That is precisely the behavior Hawbaker's second position already produces. The narrow "release-only" concept the specification distinguishes over Hawbaker is therefore not what the granted claim covers. This materially strengthens any § 103 attack.


4. Level of ordinary skill (PHOSITA)

A person with ~3–5 years of experience designing AR‑pattern fire-control groups, or a bachelor's in mechanical engineering plus 2 years of such experience, familiar with the AR‑15/M16 trigger/disconnector/safety-selector architecture. This is a mature, crowded, incremental mechanical art — KSR's "predictable variations" rubric applies with force.


5. Scope and content of the prior art

Hawbaker, US 8,667,881 B1 / 8,820,211 B1 (verified). Single trigger system with a selector giving two modes. Express disclosure: "One mode allows normal semi-automatic operation, in which the firearm fires one round with a pull of the trigger and resets trigger with release of trigger, and another mode which fires a round with a pull of the trigger and fires another round with trigger release, thus doubling rate of fire." Core parts: "a trigger, a primary disconnector, a secondary disconnector, a hammer, a selector cam, a selector lever, a detent spring and detent ball" — i.e., a plurality of retention facilities (primary disconnector, secondary disconnector, trigger sear). It expressly targets AR‑15/AR‑10 "forward hammer engagement surface" platforms and expressly addresses the machine-gun/hammer-follow problem. Critically, the selector cam's shaft "passes through the trigger" and the lever is "fastened to the bottom of the selector cam by a cross pin" — the selector is (i) two pieces and (ii) mounted on the trigger, inside the trigger guard.

Deckard, US 6,966,138 B1 (verified). "Double‑fire" conversion producing "two shots … with a single pull and release of a trigger" by increasing the gap between the safety‑sear and trigger‑sear notches.

Jones, US 2,136,511 (verified). A "release and pull trigger mechanism": main sear on the trigger (claim 1), a second sear "pivoted to the frame," and a third sear on the trigger, switchable via a manually pressed detent (arm 20). Teaches (a) dual pull/release firing, (b) mode switching, and (c) a retention facility pivoted to the frame.

Cason, US 9,146,066 B1 (verified). A bi‑directional disconnector with a forwardly directed hammer hook plus a fire selector having an "operational portion" and an "extension lever," with a fire control recess, movable between safe and fire orientations, mounted in the lower receiver. This is a frame‑mounted, apparently unitary selector acting on a retention facility.

Young US 2,027,950; H&K US 6,125,735. Listed as cited art. I did not independently verify the disclosure of H&K '735 (search budget exhausted), so I do not rely on it as a primary reference in the combinations below. Young is a generic early "Gun" patent.


6. Combinations and reasons to combine

Combination A (strongest): Hawbaker '881/'211 in view of Cason '066, optionally with Jones '511

Limitation Where met
L1 frame Hawbaker (receiver/lower), Cason
L2–L4 Hawbaker: hammer between cocked/fired, spring‑biased; trigger forward/rearward
L5 Cason: a unitary fire selector (operational portion + finger lever) mounted to the frame/lower receiver with a fire‑control recess. Alternatively, the ubiquitous one‑piece AR‑15/M16 safety selector — an admitted, well‑known element in this art.
L6 Hawbaker: primary disconnector + secondary disconnector + trigger sear
L7a Hawbaker first position, verbatim
L7b Hawbaker second position, verbatim, reinforced by Deckard '138
L8 Weakest link — see below; Jones '511 shows sears pivoted to the frame, but not a cam surface per se.

Motivation (KSR): The specification itself supplies the motivation, and it is not hindsight. Franklin Armory's own Background states the need for a trigger group "that places the selector lever outside of the trigger guard and enables the firearm to be placed in safe mode even if the trigger has been pulled in double/binary fire mode," and criticizes Hawbaker because its mode selector "is located on the trigger" and "must be manipulated within the trigger guard," with an attendant risk of accidental discharge, and because after a pull in double‑fire mode the user "cannot place the firearm in safe mode." Those are the exact two deficiencies of Hawbaker. Moving a mode selector from the trigger to the frame is (i) a predictable relocation of a known element, (ii) implemented by the art's pre‑existing frame‑mounted safety selector (Cason; standard AR‑15), and (iii) a recognized, finite set of solutions to a known problem. KSR at 421, 425.

Secondary teaching/where the frame cam surface can come from: U.S. 2016/0018176 A1 discloses the housing "cam surface 146" engaged by the backup disconnector's cam pin — i.e., exactly L8. But (i) it is the applicant's own commonly owned disclosure, (ii) it published 2016‑01‑21, after the 2015‑11‑03 critical date, and (iii) it therefore appears to be excepted under § 102(b)(2)(C). An examiner or challenger cannot safely rest L8 on it. If it is disqualified, L8 must be met by (a) Cason's frame‑mounted selector recess interacting with the disconnector, or (b) an argument that a cam surface on the housing engaging a pivoting retention member is an obvious/known expedient — an argument I assess as arguable but not clean.

Combination B: Jones '511 in view of Hawbaker '881

Jones teaches the pull‑and‑release dual function and mode switching from the 1930s, with a sear pivoted to the frame. Hawbaker upgrades that to a modern, drop‑in, AR‑15‑compatible module with plural disconnectors and a detented selector. The motivation is the same field, same problem (doubling rate of fire without a machine‑gun classification), and the same known solution set. L5 and L8 remain the vulnerable points and again require Cason or the conventional selector.

Combination C: Deckard '138 in view of Hawbaker '881 and Cason '066

Deckard shows the release‑fire result; Hawbaker shows selectability and AR‑15 compatibility; Cason shows the frame‑mounted single‑piece selector. This is essentially Combination A with a different secondary reference for L7b.


7. The two limitations that carry the claim

  1. L5 — "a selector consisting of a single piece connected to the frame." This was the drafter's deliberate narrowing over Hawbaker (two pieces; carried on the trigger). It is met only by a secondary reference (Cason '066, or the conventional AR‑15 safety selector). A challenger must show that substituting the art's standard single‑piece frame‑mounted safety selector for Hawbaker's trigger‑mounted mode selector was obvious — which is well supported by the applicant's own admitted motivation, but is the limitation an infringement defendant would attack hardest.
  2. L8 — "the frame including a cam surface operably engaged by at least one of the retention facilities." The best evidence is the applicant's own disqualified disclosure. Absent it, this is the claim's strongest redoubt and the most likely basis for surviving a § 103 challenge on the cited-art record.

8. Secondary considerations (brief)

Potential pro‑patentability evidence exists: commercial success of the BFS™ product line, industry copying (the Franklin Armory enforcement actions noted in the earlier section, e.g. Franklin Armory v. No B.S. Accessories, No. 2:24‑cv‑01395 (D. Nev.)), and the notable fact that ATF/BATFE did not classify the pull‑then‑release system as a machine gun — a regulatory-clearance consideration the specification foregrounds.

Two cautions for nexus: (i) the specification admits Hawbaker already achieved selectable pull‑then‑release dual mode, so the "double‑fire capability" per se cannot carry nexus — only the selector architecture (L5) and backup-disconnector/frame-cam safety features (L8) can; and (ii) regulatory classification is generally treated as a market/legal factor, not a classic "unexpected result," unless tied to a claimed structural difference. An opposing expert would argue the alleged copying is of the function (double fire), which is old in Jones '511 and Deckard '138, rather than of the claimed structure.


9. Conclusion and confidence

  • L1–L4, L6, L7a, L7b: strong § 103 case. Hawbaker '881/'211 alone discloses nearly all of these, including the exact "pull fires, release fires" second mode that the granted claim recites (as corrected in § 3, the claim is broader than the Summary/Abstract wording). Deckard and Jones corroborate.
  • L5: moderate‑to‑strong § 103 case via Cason '066 or a conventional single‑piece AR‑15 safety selector, with motivation supplied by the applicant's own admitted criticisms of Hawbaker.
  • L8: weak‑to‑moderate on the cited-art record. The cleanest reference (US 2016/0018176 A1) is the applicant's own commonly owned, post‑critical‑date publication and is very likely disqualified under AIA § 102(b)(2)(C). I could not verify H&K '735's disclosure (search budget exhausted) and therefore do not rely on it.

Net assessment: A prima facie obviousness case is available and, on this record, likely sustainable against every limitation except L8, which is the crux. A challenger should (a) develop non-family prior art showing a housing/housing‑pocket cam surface engaged by a pivoting disconnector, or (b) argue L8 is a predictable design choice for guiding a pivoting retention member. Without one of those, I would not predict invalidation of the granted claim on the cited references alone.

Uncertainties I will not paper over: I did not verify the disclosures of US 2,027,950, US 6,125,735, US 9,810,496, or US 9,551,546; I did not verify the claim texts of the parent patents ('013, '881) or the pending continuation US 17/562,112; and the common‑ownership status at the 2015‑11‑03 critical date is inferable from the assignment record but not conclusively established by it.

Generated 9/29/2026, 11:52:35 PM

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