Rare Breed Triggers v. Crawford: Consent Judgment & Permanent Injunction on Forced Reset Trigger Patent
Rare Breed Triggers, LLC and ABC IP LLC brought a patent infringement action against six defendants — including machining companies and individuals — over the Para-15 Drop-In Trigger and related forced reset trigger products. The case resolved after 748 days via a consent judgment that permanently enjoins all defendants from making, using, or selling any product covered by US10514223B1.
Forced Reset Trigger Dispute Ends in Binding Consent Judgment
Filed on January 13, 2023 in the Northern District of Oklahoma, this infringement action was brought by Rare Breed Triggers, LLC and ABC IP LLC against seven defendants — including Madison Crawford, David Gormley, Nathan Gormley, Henn Industries LLC, Mac 6 Machining LLC, MDN Unlimited Inc., and Revolution Precision Machining LLC. The plaintiffs alleged infringement of US10514223B1, a patent covering forced reset trigger mechanisms, specifically targeting the Para-15 Drop-In Trigger product and comparable offerings.
The case closed on January 30, 2025 via a Consent Judgment and Permanent Injunction stipulated by all parties. All claims against all defendants were dismissed with prejudice, and defendants — including successors, assigns, subsidiaries, and related entities — are permanently enjoined from making, using, importing, offering for sale, or selling any product covered by any claim of the ‘223 Patent for the patent’s remaining term. The injunction terminates automatically only upon patent expiration or a final unappealable invalidity ruling.
At 748 days, the case ran for over two years before resolving short of trial, suggesting that settlement negotiations alongside the litigation were substantive and complex — particularly given the number of defendants. Notably, the consent judgment explicitly extends issue preclusion, claim preclusion, res judicata, and collateral estoppel to all defendants, barring any future challenge to the ‘223 Patent’s validity, enforceability, or infringement in courts or Patent Office proceedings. The confidential settlement agreement underlying the judgment means financial terms, if any, remain undisclosed.
Filing to Consent Judgment in 748 days
748 days — above median for patent cases in the Northern District of Oklahoma
Consent judgment and permanent injunction: what the order means for both parties
Consent judgment: stipulated finality with injunctive force
A consent judgment is a court-entered order agreed to by all parties, carrying the same legal weight as a litigated judgment. Here, the parties stipulated to both a permanent injunction and dismissal with prejudice. Unlike a simple settlement, this order is directly enforceable by the court. Violations expose defendants to contempt proceedings without requiring plaintiffs to refile. The court explicitly retained jurisdiction for compliance enforcement.
Dismissed with prejudicePlaintiffs secure permanent injunction and full issue preclusion
Rare Breed Triggers and ABC IP LLC achieved a commercially strong outcome: a permanent injunction barring all named defendants and their successors from any activity touching the ‘223 Patent’s claims. Critically, the order bars defendants from ever challenging the patent’s validity, enforceability, or infringement in any future court or Patent Office proceeding — including IPR — giving plaintiffs an unusually durable shield against downstream attacks on the patent.
Patent enforceability preservedDefendants bound by sweeping preclusion and successor liability
All seven defendants are permanently enjoined and cannot relitigate any issue resolved here. The order explicitly binds successors, assigns, subsidiaries, and related entities — meaning corporate restructuring or asset transfers do not escape the injunction. Defendants also waived any right to petition the Patent Office for reexamination or IPR of the ‘223 Patent. The confidential settlement may include royalties or other terms not visible from the public record.
No further challenge permittedStrengthened enforcement posture for forced reset trigger IP
The breadth of this consent judgment — covering machining companies, distributors, and individuals — signals an active enforcement strategy by Rare Breed Triggers against the aftermarket forced reset trigger supply chain. For competing manufacturers, the explicit extension of collateral estoppel to Patent Office proceedings raises the barrier to any IPR-based challenge strategy. Any company currently making or selling forced reset trigger products should treat US10514223B1 as a materially enforced patent.
High enforcement risk for FRT marketFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Rare Breed Triggers, LLC | Company | Firearm trigger technology licensor — holder of US10514223B1 covering forced reset triggersSearch in Eureka ↗ |
| Co-Plaintiff | ABC IP LLC | Company | Search in Eureka ↗ |
| Defendant | Madison Crawford | Individual | Multiple machining companies and individuals alleged to have made or sold forced reset trigger productsSearch in Eureka ↗ |
| Co-Defendant | David Gormley | Individual | Search in Eureka ↗ |
| Co-Defendant | Henn Industries, LLC | Company | Search in Eureka ↗ |
| Co-Defendant | Mac 6 Machining, LLC | Company | Search in Eureka ↗ |
| Co-Defendant | MDN Unlimited, Inc. | Company | Search in Eureka ↗ |
| Co-Defendant | Nathan Gormley | Individual | Search in Eureka ↗ |
| Co-Defendant | Revolution Precision Machining, LLC | Company | Search in Eureka ↗ |
| Plaintiff counsel | Charles D. Pfister | Attorney | Counsel for Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Colin Hampton Tucker | Attorney | Counsel for Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Glenn D Bellamy | Attorney | Counsel for Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rhodes Hieronymus Jones Tucker & Gable PLLC | Law Firm | Representing Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Taft, Stettinius & Hollister LLP | Law Firm | Representing Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Wood, Herron & Evans LLP | Law Firm | Representing Rare Breed Triggers, LLCSearch in Eureka ↗ |
| Defendant counsel | Kevin Brian Joyce | Attorney | Counsel for Madison CrawfordSearch in Eureka ↗ |
| Defendant law firm | Joyce Law Firm | Law Firm | Representing Madison CrawfordSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Oklahoma Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The consent judgment is notable for its breadth and finality. The permanent injunction extends beyond named defendants to their successors, assigns, and related entities — an unusually wide net that limits restructuring as an escape route. The explicit estoppel provisions covering Patent Office proceedings, including IPR and reexamination, are not standard consent judgment language and reflect deliberate drafting by plaintiffs’ counsel to foreclose all downstream validity challenges. The confidential settlement agreement incorporated by reference suggests financial terms were agreed separately, though none appear on the public docket.
US10514223B1 — Forced Reset Trigger Mechanism for Semi-Automatic Firearms
US10514223B1, filed under application number US16/143624, claims a forced reset trigger (FRT) mechanism — a drop-in trigger assembly designed for semi-automatic firearms that resets the trigger under mechanical force rather than relying solely on the shooter releasing pressure. The technology sits at the intersection of firearms mechanics and precision machining. The patent was granted to ABC IP LLC and exclusively licensed to Rare Breed Triggers, LLC for commercial exploitation. Its claims cover the trigger mechanism broadly enough to capture aftermarket drop-in assemblies such as the Para-15.
Forced reset triggers have attracted significant regulatory and commercial attention, making the IP position around them highly contested. For competing manufacturers — particularly small machining shops producing aftermarket trigger components — this patent represents a credible enforcement risk backed by demonstrated litigation willingness across multiple defendants simultaneously. The breadth of the permanent injunction secured in this case, combined with the estoppel provisions, suggests the patent holder views US10514223B1 as a cornerstone asset and will continue to enforce it aggressively against any entrant producing functionally equivalent trigger assemblies.
Should you run an FTO analysis against US10514223B1?
Any company designing, manufacturing, or distributing drop-in trigger assemblies for semi-automatic firearms — particularly forced reset or mechanically reset variants — should treat US10514223B1 as an active enforcement risk. This case demonstrates that plaintiffs are willing to pursue machining subcontractors, distributors, and individual operators, not just primary manufacturers. If your product resets a trigger under mechanical force or operates on a functionally similar principle, a freedom-to-operate analysis is not optional — it is prudent business practice.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US10514223B1 against your product’s technical specifications, identify design-around opportunities, and flag overlapping patents in the firearms trigger technology space. Eureka’s patent landscape tools also allow you to monitor new filings and continuations by ABC IP LLC and Rare Breed Triggers, providing early warning of portfolio expansion that could affect your product roadmap before litigation begins.
Run a freedom-to-operate analysis on US10514223B1 to assess your product’s exposure
Run FTO in Eureka →Similar forced reset trigger and firearm component patent cases
Explore related patent infringement cases involving forced reset triggers and firearm accessory technology in U.S. district courts, including comparable multi-defendant enforcement actions.
What this case signals for the forced reset trigger IP landscape
A multi-defendant enforcement sweep ending in a court-binding injunction reshapes the competitive dynamics around forced reset trigger technology.
Multi-defendant strategy signals supply-chain-level enforcement
By suing machining companies, distributors, and individuals simultaneously, the plaintiffs targeted the entire production and distribution chain for competing forced reset triggers. This approach is consistent with a deliberate effort to eliminate market alternatives rather than extract royalties from a single actor. Companies adjacent to this supply chain — even as component suppliers — face real exposure.
Issue preclusion clause makes this harder to unwind than a typical settlement
Most patent settlements leave the patent’s validity open to future challenge. This consent judgment expressly forecloses IPR, reexamination, and court challenges by all defendants and their successors. Patent challengers in this space cannot rely on defeated defendants as proxies for future invalidity attacks, which is a meaningful strategic advantage for the patent holder.
Rare v Madison — key questions answered
The consent judgment permanently enjoins all defendants — and their successors, assigns, and related entities — from making, using, importing, offering for sale, or selling any product covered by any claim of US10514223B1 for the patent’s remaining term. All claims were dismissed with prejudice. Defendants also waived any right to challenge the patent’s validity or enforceability in any future court or Patent Office proceeding.
No. The consent judgment explicitly extends issue preclusion, claim preclusion, res judicata, and collateral estoppel to Patent Office proceedings including inter partes review and reexamination. Named defendants — and their successors and assigns — are barred from contending in any forum that the ‘223 Patent is invalid, unenforceable, or not infringed. Third parties not bound by this order remain free to petition the Patent Office.
A forced reset trigger (FRT) is a drop-in trigger assembly for semi-automatic firearms that mechanically forces the trigger forward to reset after each shot. US10514223B1 claims this mechanism and has been actively enforced by Rare Breed Triggers and ABC IP LLC against multiple aftermarket manufacturers. The patent’s enforceability was affirmed by this consent judgment, making it a material risk for any company producing functionally similar trigger assemblies.
The consent judgment explicitly states it binds all successors, assigns, transferees, and entities holding by, through, or under the defendants. This means an acquirer of Henn Industries, Mac 6 Machining, MDN Unlimited, or Revolution Precision Machining would inherit the injunction and could not resume production of products covered by the ‘223 Patent without risking contempt of court. M&A due diligence in this sector should specifically review this order.
The 748-day duration suggests substantive litigation activity — including likely discovery, claim construction briefing, and parallel settlement negotiations — before the parties reached agreement. Multi-defendant patent cases typically require additional coordination time to align all parties on joint settlement terms. The confidential settlement agreement referenced in the consent judgment may reflect complex financial or licensing terms that took time to negotiate, though those terms are not publicly disclosed.
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