Patent 12038247
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
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Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
Obviousness Analysis of U.S. Patent No. 12,038,247
Date of Analysis: April 29, 2026
Patent Under Review:
- Patent Number: US 12,038,247 B2
- Title: Firearm trigger mechanism
- Filing Date: May 30, 2023
- Priority Date: September 8, 2022
- Inventor: Brian A. Blakley
- Assignee: ABC IP, LLC
Introduction
This analysis examines the patentability of the claims of U.S. Patent No. 12,038,247 ('247 patent) in light of prior art, specifically under the legal standard of non-obviousness as defined in 35 U.S.C. § 103. The '247 patent describes a "three position" trigger mechanism for AR-pattern firearms, featuring a safe mode, a standard semi-automatic mode, and a forced reset semi-automatic mode. The key inventive concept appears to be the integration of a selectable disconnector function, which allows the user to switch between a conventional semi-automatic operation and a "forced reset" operation, all within a single trigger assembly.
Legal Standard for Obviousness (35 U.S.C. § 103)
A patent claim is considered obvious if the differences between the claimed invention and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art (POSA). This analysis requires considering the scope and content of the prior art, the differences between the prior art and the claims at issue, and the level of ordinary skill in the pertinent art. A key consideration is whether there would have been a reason or motivation for a person of ordinary skill in the art to combine the teachings of the prior art references to arrive at the claimed invention.
Prior Art Analysis and Combination
The primary prior art references relevant to this analysis are U.S. Patent No. 7,398,723 B1 to Blakley (Blakley '723) and U.S. Patent No. 9,939,221 B2 to Graves (Graves '221).
Blakley '723: This patent, by the same inventor, is the foundational reference for the forced reset mechanism. It discloses a firearm trigger that uses a pivoting cam actuated by the bolt carrier to push the trigger forward, thereby resetting it. This allows for a rapid rate of fire, as the user's finger does not need to be lifted off the trigger to reset the mechanism. However, Blakley '723 does not teach a multi-mode selector that allows the user to switch between this forced reset mode and a standard semi-automatic mode where the disconnector functions normally.
Graves '221: This patent discloses a firearm trigger mechanism with a selector switch that allows the user to choose between a standard semi-automatic mode and an "echo" mode, which also enables a rapid rate of fire. While the underlying mechanism for the "echo" mode (using a secondary sear) is different from the cam-based forced reset in the '247 patent, the concept of a multi-mode selector for different semi-automatic firing styles is clearly taught.
Motivation to Combine
A person of ordinary skill in the art of firearm design, presented with the '247 patent's objective of creating a versatile trigger mechanism, would have been motivated to combine the teachings of Blakley '723 and Graves '221 for the following reasons:
- Providing User Choice: The market for firearm accessories demonstrates a clear demand for user-configurable options. A shooter may desire the rapid-fire capability of a forced-reset trigger for certain applications (e.g., competition) but prefer the feel and control of a standard semi-automatic trigger for others (e.g., precision shooting).
- Combining Known Features: Blakley '723 teaches a functional forced-reset trigger. Graves '221 teaches a selector switch to alternate between different semi-automatic modes. Combining these known elements—a selectable mode switch with a known trigger mechanism—is a predictable and logical design choice to enhance functionality. The "three-position" selector (safe, semi-auto, forced-reset) is a well-established concept in firearm design, making its application to this combination a matter of routine engineering.
Obviousness Argument Against Independent Claims
Re: Claims 1, 4, 9, 14, 15, and 20
These claims describe a firearm trigger mechanism with a hammer, trigger, disconnector, and a cam that forces the trigger to reset. The core of the claims is the addition of a three-position safety selector that allows switching between a "standard semi-automatic" mode (where the disconnector functions) and a "forced reset semi-automatic" mode (where the selector prevents the disconnector from engaging the hammer).
Blakley '723 in view of Graves '221:
- Blakley '723 discloses all the essential mechanical components of the forced reset mode: a hammer, trigger, a cam that interacts with the bolt carrier, and a mechanism to reset the trigger.
- Graves '221 teaches the use of a selector switch to alternate between a standard semi-automatic mode and a rapid-fire mode.
- A person of ordinary skill in the art, seeking to add a standard semi-automatic mode to the forced-reset design of Blakley '723, would find it obvious to use a multi-position selector, as taught by Graves '221, to selectively engage or disengage the disconnector. The '247 patent's method of using a "narrow semi-circular portion" (116) on the safety selector to prevent the disconnector from pivoting is a known and straightforward mechanical implementation of such a selection function.
Detailed Breakdown by Claim Elements:
- Hammer, Trigger, Sear, Cam (Claims 1, 4, 9, 14, 15, 20): These elements and their function in a forced-reset context are substantially taught by Blakley '723.
- Disconnector (Claims 1, 4, 9, 14, 15, 20): A standard disconnector is a fundamental component of AR-pattern firearms, and its function is well-known in the art. Blakley '723 also includes a disconnector.
- Three-Position Safety Selector (Claims 1, 4, 9, 20): This is the key distinguishing feature. While Blakley '723 lacks this, Graves '221 teaches the use of a selector to switch between different firing modes. A person of ordinary skill in the art would have found it obvious to apply a similar selector mechanism to the Blakley '723 design to create a multi-mode trigger. The selector's interaction with the disconnector (preventing it from catching the hammer hook in the forced-reset mode) would be a logical and predictable way to "disable" the standard semi-automatic reset and enable the forced reset.
- Housing/Module (Claim 4, 10, 11, 16): The concept of a "drop-in" trigger module is a well-established art in the firearms industry for simplifying installation and improving performance. It represents a common and obvious design choice for packaging a trigger mechanism, not an inventive step in itself.
- Spring Biasing (Claim 3, 7, 12, 13, 17, 18): The use of springs to bias trigger components is fundamental to firearm design and would be considered an obvious and necessary element for the proper functioning of the mechanism.
Conclusion
The claims of U.S. Patent No. 12,038,247 appear to be vulnerable to an obviousness challenge under 35 U.S.C. § 103. The core forced-reset mechanism is disclosed in the inventor's own prior art (Blakley '723). The primary addition in the '247 patent is a three-position selector that allows the user to choose between standard semi-automatic and forced-reset semi-automatic modes by selectively disabling the disconnector. The concept of a multi-mode selector for a semi-automatic firearm is taught by prior art such as Graves '221. A person of ordinary skill in the art would have found it obvious to combine these known elements to create a trigger system with the claimed functionality, as it represents a straightforward combination of existing technologies to achieve a predictable result. The packaging of this mechanism into a drop-in module is also a well-known and obvious design choice in the field.
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