The complaint

The East Texas case is ABC IP, LLC v. Vukanovich, No. 4:26-cv-01235-ALM (E.D. Tex.). It began in the Northern District of Texas, Dallas Division, as No. 3:26-cv-02341, where the complaint was filed July 15, 2026 under the caption ABC IP, LLC, Rare Breed Triggers, Inc., and RBTM LLC v. Nocturnal Apparel & Co LLC and Vincent Michael Vukanovich. The plaintiffs filed a notice of multidistrict litigation filing in that court on August 31, 2026; the Judicial Panel on Multidistrict Litigation's conditional transfer order CTO-11 in MDL No. 3176 was filed in the case in early September; and the East Texas docket shows the case transferred in on September 9, 2026 and assigned to Chief District Judge Amos L. Mazzant. The complaint alleges, on information and belief, that Nocturnal Apparel & Co LLC is a Texas limited liability company and that the individual defendant is its owner or an owner and directs its operations.

Patents and accused products

The complaint asserts U.S. Patents 12,038,247, 12,031,784, 12,578,159, and 12,636,403, alleging that ABC IP owns them by assignment and that Rare Breed is the exclusive licensee. The charted claims are claim 15 of the '247 patent, claim 1 of the '784 and '159 patents, and claim 38 of the '403 patent. The accused products are the 3-Position Cornfire Arsenal M.A.R.C. Non Ambi and the 3-Position ARC-Fire, which the complaint alleges, on information and belief, the defendants sell through the nocturnalapparel.co website, and it alleges that each lets the user switch between safe, standard semiautomatic, and forced reset semiautomatic modes.

What the patents cover

Claim 15 of the '247 patent covers a firearm trigger mechanism with a hammer that has a sear catch and a hook for engaging a disconnector, a trigger member with a sear, the disconnector, and a cam with a cam lobe movable between a first and a second position, all mounted in the receiver's fire control mechanism pocket. With the cam in the first position the mechanism runs in a standard semi-automatic mode, in which the disconnector catches the hammer and the user must release the trigger to free it. With the cam in the second position the cam lobe forces the trigger member toward its set position and the disconnector is prevented from catching the hammer, so the user can pull the trigger again once the bolt carrier returns to battery, a forced reset semi-automatic mode.

Trademark counts and relief

The complaint adds federal trademark infringement under 15 U.S.C. 1114, false designation of origin under 15 U.S.C. 1125(a), and common law trademark infringement and unfair competition, alleging that RBTM owns the FRT Marks, that Rare Breed is the exclusive licensee, and, on information and belief, that the defendants promote products in association with those marks. The prayer asks for preliminary and permanent injunctions, damages with enhancement, trademark remedies, and attorneys' fees, and the plaintiffs demand a jury.

What to watch next

The defendants answered the complaint on October 16, 2026 (ECF No. 17). Watch for MDL scheduling orders and any motions in the transferee court.