Obviousness

Obviousness Analysis for US Patent 12036336 under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the claims of US Patent 12036336 obvious to a person having ordinary skill in the art (POSA). The motivation for combining these references stems from the common desire in the firearms industry to increase the rate of semi-automatic fire, enhance user control, and ensure safety, as explicitly articulated in the background and summary of US12036336 itself.

The primary combination for rendering the independent claims obvious is US 10,514,223 and US 11,346,627 (collectively, "the '223/'627 patents") in view of US Provisional Patent Application No. 63/374,941 to Blakley ("Blakley Provisional").

Claim 1: Firearm Trigger Mechanism

Combination of References: US 10,514,223 and US 11,346,627 in view of US Provisional Patent Application No. 63/374,941.

Analysis:

1. Core Forced Reset and Locking Mechanism: The '223/'627 patents, explicitly cited in the background of US12036336, describe devices where "the hammer forces the trigger to the set position, and a locking bar prevents early hammer release." This directly teaches the following key elements of Claim 1:

   • A hammer having a sear catch and a hook for engaging a disconnector, adapted to be pivoted rearward by rearward movement of a bolt carrier.
   • A trigger member having a sear, with a surface positioned to be contacted by the hammer during its rearward pivoting to force the trigger member to the set position.
   • The engagement and disengagement of the sear and sear catch.
   • A disconnector with a hook for engaging the hammer.
   • A locking member (described as a "locking bar") pivotable between a first position (blocking trigger movement) and a second position (allowing trigger movement), spring-biased toward the first position, and moved to the second position by contact from the bolt carrier during its forward movement as it reaches a substantially in-battery position. This locking member's function is to prevent early hammer release.

2. Three-Position Safety Selector and Forced Reset Functionality: The Blakley Provisional (U.S. Provisional Patent Application No. 63/374,941, filed Sep. 8, 2022) is also cited in US12036336, stating that it "incorporates a three-position safety selector and associated structure to provide safe, standard semi-automatic, and forced reset semi-automatic modes." This teaches:

   • A safety selector adapted to pivot between safe, standard semi-automatic, and forced reset semi-automatic positions.
   • The functionality in the standard semi-automatic position where the disconnector catches the hammer, requiring manual trigger release for reset.
   • The functionality in the forced reset semi-automatic position where the trigger is forced to the set position, and the safety selector prevents the disconnector hook from catching the hammer hook, allowing the user to pull the trigger without manual release once the bolt carrier is in-battery.

Motivation for Combination:
A person having ordinary skill in the art (POSA) would be motivated to combine the teachings of the '223/'627 patents with the Blakley Provisional for several reasons:

• Addressing Known Desires: US12036336 explicitly states that "Further improvement in forced reset triggers is desired" and that "shooters desire to increase the rate of semiautomatic fire." The '223/'627 patents offered a mechanism for increased rate of fire via hammer-forced reset and a locking bar for safety.
• Enhancing Versatility and User Control: The Blakley Provisional presented a significant advancement by integrating a three-position safety selector to provide selectable modes, including a dedicated forced reset semi-automatic option alongside a standard semi-automatic and safe mode. A POSA would recognize the benefit of combining the robust hammer-driven reset and early release prevention taught by the '223/'627 patents with the user-selectable firing modes of the Blakley Provisional. This combination would yield a more versatile and user-friendly firearm trigger mechanism capable of both traditional semi-automatic operation and a high-rate-of-fire forced reset mode, fulfilling the desire for "further improvement in forced reset triggers."
• Obvious Design Choice for Disconnector Disable: In a forced reset semi-automatic mode, the disconnector's function (holding the hammer until the trigger is released) is inherently counterproductive to the goal of rapid firing without releasing the trigger finger. Therefore, it would be an obvious design choice for a POSA, when implementing a forced reset mode with a safety selector (as taught by Blakley Provisional), to configure the safety selector to disable the disconnector in that mode. The specific mechanical means for doing so, such as a protuberance on the safety selector contacting the disconnector (as described in US12036336), would be a routine engineering decision.

Therefore, Claim 1 of US12036336 would have been obvious to a POSA by combining the '223/'627 patents with the Blakley Provisional.

Claim 3: Firearm Trigger Mechanism with Housing

Combination of References: US 10,514,223 and US 11,346,627 in view of US Provisional Patent Application No. 63/374,941, further combined with the general knowledge of modular trigger housings in AR-pattern firearms.

Analysis:
Claim 3 adds the limitation that the trigger mechanism components (hammer, trigger member, disconnector, locking member) are mounted within a housing adapted to fit into a receiver's fire control mechanism pocket, forming a "drop-in" module.

Motivation for Combination:
US12036336 explicitly states that the present invention "is particularly adaptable for construction as a 'drop-in' replacement trigger module that only requires insertion of two assembly pins and the safety selector." The patent also notes that "Lower receiver parts not important to the present invention are well-known in the art and are omitted from the figures for clarity." The concept of drop-in trigger modules for AR-pattern firearms was well-established and a common design practice in the art by the priority date of US12036336. A POSA, seeking to provide the combined forced reset and multi-mode trigger mechanism (as rendered obvious for Claim 1) in a convenient and easily installable format for popular firearm platforms like AR-pattern firearms, would be motivated to package these components within a self-contained housing. This modular design offers advantages in manufacturing, installation, and user customization, and thus constitutes an obvious engineering choice.

Claim 7: Firearm

Combination of References: US 10,514,223 and US 11,346,627 in view of US Provisional Patent Application No. 63/374,941, implemented within a firearm comprising a receiver and reciprocating bolt carrier.

Analysis:
Claim 7 describes a complete firearm incorporating the trigger mechanism, including a receiver and a reciprocating bolt carrier. The functional aspects of the hammer, trigger member, disconnector, locking member, and safety selector are identical to Claim 1.

Motivation for Combination:
The very nature and purpose of the trigger mechanisms described in the '223/'627 patents and the Blakley Provisional, as well as US12036336 itself, are to function within a firearm. All these references describe mechanisms for increasing the rate of fire in semi-automatic firearms by interacting with the bolt carrier. Therefore, it would be inherently obvious for a POSA to incorporate the combined trigger mechanism (as rendered obvious for Claim 1) into a standard firearm receiver with a reciprocating bolt carrier, as this is the intended environment and application for such a device. This claim simply articulates the intended use of the previously described mechanism within its necessary operational context.

Claim 12: Firearm Trigger Mechanism with Movable Locking Member

Combination of References: US 10,514,223 and US 11,346,627 in view of US Provisional Patent Application No. 63/374,941, further considering the explicit disclosure within US12036336 regarding alternative locking member designs.

Analysis:
Claim 12 is similar to Claim 1 but broadens the description of the locking member, stating it is "movably mounted" rather than specifically "pivotable on a transverse locking member pivot axis." This broader language encompasses both pivoting and sliding mechanisms.

Motivation for Combination:
The '223/'627 patents teach a "locking bar" to prevent early hammer release. While the detailed description of US12036336 shows a pivotable locking member (72), it explicitly states that "Alternatively, the locking/blocking member 72 can be slidably mounted to the housing 12 and spring biased forward by a compression spring." This shows that both pivoting and sliding mechanisms for achieving the same locking function were known or obvious alternatives to the inventor at the time of filing. A POSA, when designing a mechanism to block and unblock trigger movement based on bolt carrier position, would routinely consider various kinematic solutions, including pivoting and sliding, based on design constraints like available space, manufacturing processes, and desired component interaction. Therefore, replacing a pivoting locking member with a slidably mounted one (or vice versa), while maintaining the same functional relationship with the bolt carrier and trigger, would be an obvious design choice for a POSA.

In summary, the core inventive concepts of US12036336, namely the hammer-forced trigger reset, the bolt-carrier-actuated locking member to prevent early release, and the three-position safety selector with a dedicated forced reset mode that bypasses the disconnector, are either directly taught or rendered obvious by the combination of US 10,514,223 / US 11,346,627 and US Provisional Patent Application No. 63/374,941, along with the general knowledge in the field regarding modular firearm components and mechanical design alternatives.