ABC IP and Rare Breed's Wyoming Suit Against Grey Market Research & Development Moves Into the East Texas MDL, Where an Answer Follows a Clerk's Default.

The East Texas case is ABC IP, LLC v. Grey Market Research & Development, LLC, No. 4:26-cv-01448 (E.D. Tex.). It began in the District of Wyoming, Casper Division, as No. 2:26-cv-00189, where the complaint was filed June 17, 2026. The Clerk of the Judicial Panel on Multidistrict Litigation finalized conditional transfer order CTO-14 on October 6, 2026, and the East Texas docket shows the case transferred in on October 8, 2026 for In re Rare Breed Triggers Patent Litigation, MDL No. 3176, and assigned to Chief District Judge Amos L. Mazzant III.

The only defendant is Grey Market Research & Development, LLC, which the complaint alleges, on information and belief, is a Wyoming limited liability company based in Sheridan, Wyoming.

Patents and the accused product

The complaint asserts U.S. Patents 12,038,247, Firearm Trigger Mechanism, issued July 16, 2024; 12,031,784, Adapted Forced Reset Trigger, issued July 9, 2024; 12,529,538, Safety Mechanism for Firearm, issued January 20, 2026; 12,578,159, Firearm Trigger Mechanism, issued March 17, 2026; 12,636,403, Firearm Trigger Mechanism, issued May 26, 2026. It alleges that ABC IP owns them by recorded assignment and that Rare Breed is the exclusive licensee. It alleges, on information and belief, that the defendant sells a three-position "Super Safety" through its website as a partial kit or a complete kit, and that the device lets the user switch between safe, standard semi-automatic, and forced reset semi-automatic modes. It charts the Super Safety against claim 15 of the '247 patent, claim 1 of the '784, '538, and '159 patents, and claim 38 of the '403 patent.

What the patents cover

Claim 15 of the '247 patent covers a firearm trigger mechanism with a hammer, a trigger member, a disconnector, and a cam with a cam lobe movable between two positions. In the first position the mechanism runs in a standard semi-automatic mode, where the user must release the trigger to free the hammer from the disconnector; in the second the cam lobe forces the trigger toward its set position and the disconnector is kept from catching the hammer, a forced reset semi-automatic mode. Claim 1 of the '784 patent covers, in a forced reset trigger mechanism, an extended trigger member locking device whose locking member moves between a position that locks the trigger against pulling and a position that does not, is moved by contact with the bolt carrier, and has a body portion and an upwardly extending deflectable portion that moves separately from the body.

Claim 38 of the '403 patent covers a forced reset trigger mechanism with a hammer, a disconnector, a trigger member, and a safety selector movable between a standard semi-automatic position and a forced reset semi-automatic position; in the standard position, after the hammer pivots back past the disconnector hook, the user must ease rearward pressure on the trigger before it can be pulled to fire again.

Default, transfer, and answer

The Wyoming docket shows the defendant served on June 26, 2026 with an answer due July 17. The plaintiffs moved for entry of default on August 6, and the Wyoming clerk entered default on August 7, 2026 (ECF No. 17). After the transfer, the East Texas docket shows a jury demand by Grey Market Research & Development, LLC and an entry titled answer to complaint and counterclaim (ECF No. 25), both on October 19, 2026.

The plaintiffs allege direct, induced, and contributory infringement, much of it on information and belief, and willfulness. They ask for preliminary and permanent injunctions, damages with enhancement under 35 U.S.C. 284, and attorneys' fees, and demand a jury.

What to watch next

Watch for the plaintiffs' answer to the counterclaim, any motion addressing the Wyoming default, and MDL-wide orders that apply to the case. The case can end at any time, including by settlement or voluntary dismissal.