The litigation involves seven patents owned by ABC IP LLC and exclusively licensed by Rare Breed Triggers Inc., targeting aftermarket firearm components known as forced reset triggers that allow shooters to achieve significantly higher rates of fire. The patent holders have sued multiple manufacturers across five federal districts, alleging infringement by devices including the Super Safety FRT, Defender FRT, Partisan Disruptor, and Atrius Forced Reset Selector. The cases involve millions in potential damages and requests for injunctive relief that could shut down production of the accused devices.
The panel found that centralization was warranted despite defendants' arguments that the cases should remain separate or be divided into product-specific MDLs. As the panel explained, 'We find that centralization under Section 1407 will eliminate duplicative discovery, prevent inconsistent pretrial rulings—especially regarding claim construction, patent validity, and the appropriateness of injunctive relief—and conserve the resources of the parties, their counsel, and the judiciary.' The panel rejected requests to limit the MDL's scope to cases involving only the Super Safety device and U.S. Patent No. 12,038,247.
The panel delivered sharp criticism to defendants seeking to fragment the litigation, writing that 'overly restricting this litigation's scope at the outset risks undermining a key reason for centralizing patent cases asserting overlapping patents—to prevent inconsistent pretrial rulings (particularly with respect to claim construction and patent validity issues).' The panel noted that even if multiple products are involved, 'differences in the accused products and infringement allegations in the cases do not prevent centralization where common factual issues involving claim construction and patent validity are shared.'
The six initial cases were filed between 2025 and 2026 across five districts, with an additional 24 potential tag-along actions pending in sixteen districts. Defendants had argued that managing multiple products and seven patents from four distinct families would make the litigation unmanageable, but the panel dismissed these concerns, noting that the transferee judge 'can employ any number of pretrial techniques—such as establishing separate discovery or motion tracks for the different devices—to efficiently manage this multi-patent, multi-product litigation.'
Multiple defendant groups opposed centralization, with some seeking separate MDLs for their specific products. The Disruptor defendants requested separate centralization in Wyoming for cases involving the Partisan Disruptor device, while the Atrius defendants sought a separate MDL in the Western District of Texas for the Atrius Forced Reset Selector cases. The panel found it 'premature to rule on their inclusion in this MDL' since those cases were not part of the initial motion, but indicated the conditional transfer process could add them later.
A key factor in the panel's decision was a 2025 settlement between Rare Breed Triggers and the Department of Justice that ended federal criminal litigation over the company's FRT-15 device. Under that agreement, Rare Breed committed to 'take all reasonable efforts to engage in patent enforcement seeking prohibitory injunctions' against FRT manufacturers, while the DOJ agreed to 'consider filing statements in support of civil actions for injunctions against patent violators.' The panel warned that limiting the MDL's scope 'may unnecessarily multiply the number of courts having to evaluate how any statements of interest that the DOJ may file affect the public interest in plaintiffs' requests for preliminary injunctions.'
The panel assigned the MDL to U.S. District Judge Amos L. Mazzant III in the Eastern District of Texas, noting he 'is well-versed in complex patent litigation, but has not yet had the opportunity to preside over a multidistrict litigation.' The Eastern District of Texas was chosen because Rare Breed Triggers is Texas-based, inventors on two patents reside in Texas, and several potential tag-along actions are already pending there. The panel also renamed the litigation from 'Super Safety Patent Litigation' to 'Rare Breed Triggers Patent Litigation' to better reflect its broader scope.
The centralization comes as the firearms industry faces increased scrutiny over devices that effectively increase firing rates while remaining technically legal under federal law. The outcome of this litigation could significantly impact the forced reset trigger market and establish precedents for how courts handle patent enforcement in the firearms accessories space, particularly given the DOJ's stated interest in supporting injunctions that advance public safety.