ABC IP, LLC et al v. Tactical Solutions Group, LLC et al
Case Overview
- Case Name: ABC IP, LLC et al. v. Tactical Solutions Group, LLC et al.
- Court: U.S. District Court for the Southern District of Ohio (Dayton Division)
- Case Number: 3:26-cv-00165
- Filing Date: June 3, 2026
- Plaintiffs: ABC IP, LLC; Rare Breed Triggers, Inc.; and RBTM LLC
- Defendants: Tactical Solutions Group, LLC; Christina Michelle Burke; and Ivan Burke
- Nature of Action: Civil lawsuit alleging willful patent infringement, federal and common law trademark infringement, false designation of origin, and unfair competition with a demand for a jury trial.
Executive Summary
Plaintiffs ABC IP, LLC (the patent owner), Rare Breed Triggers, Inc. (the exclusive licensee), and RBTM LLC have filed a comprehensive multi-count lawsuit against Ohio-based firearms retailer and manufacturer Tactical Solutions Group, LLC (TSG) and its corporate principals, Christina Michelle Burke and Ivan Burke. The federal complaint alleges that the Defendants are actively manufacturing, importing, marketing, advertising, and selling unauthorized forced-reset components—specifically the “Super Safety” trigger component kit configurations, related firearms parts, and aftermarket modification systems.
Plaintiffs contend that these products directly infringe upon their extensive intellectual property portfolio protecting “forced reset trigger” (FRT) firearm innovations. Furthermore, the suit alleges that the Defendants are wrongfully trading on the massive market goodwill of the registered “FRT” trademark to mislead consumers by advertising non-original items using Rare Breed’s brand identity. Because the Defendants reportedly continued marketing and distributed these items despite clear knowledge of the patents and trademarks, the Plaintiffs are accusing them of willful infringement, opening the door for enhanced damages.
The Technology in Dispute
The lawsuit centers on advanced firearm trigger engineering—specifically the mechanical transition from standard semi-automatic mechanisms to patented forced reset trigger (FRT) assemblies:
Standard Semi-Automatic Trigger: Relies on a traditional disconnector mechanism. When a round is fired, the user must manually release rearward finger pressure on the trigger so the disconnector can hand the hammer back off to the main trigger sear before the firearm can be discharged again.
Forced Reset Mechanism (The Patented Invention): Eliminates the necessity of traditional disconnector dependency during accelerated sequences. Instead, it utilizes specialized locking bars, cams, or lever systems cycled directly by the firearm’s reciprocating bolt carrier. This mechanically forces the trigger forward into its set reset position during the action cycle, allowing for an accelerated, highly efficient firing sequence without converting the firearm into an automatic weapon.
Breakdown of Infringement Claims
Patent Infringement (Counts I – V)
The complaint asserts that Tactical Solutions Group’s product offerings (sold via tsgguns.com) infringe upon five distinct U.S. Patents owned by ABC IP, LLC:
| Count | Asserted Patent | Technical / Mechanical Focus of Claim |
| Count I | U.S. Patent No. 12,038,247 | Overarching dual-mode trigger utilizing a moving cam lobe to physically force the trigger member back into its set position. |
| Count II | U.S. Patent No. 12,031,784 | Extended trigger locking device featuring an upwardly extending deflectable lever arm actuated by direct contact with the cycling bolt carrier. |
| Count III | U.S. Patent No. 12,529,538 | A safety mechanism employing a multi-recess cam selector configured to operate between three distinct modes to allow, modify, or block trigger movement. |
| Count IV | U.S. Patent No. 12,578,159 | Novel firearm mechanism for accelerating firing sequences utilizing multi-mode operations and specific internal sear surface geometries. |
| Count V | U.S. Patent No. 12,636,403 | Structural claim focusing on a multi-position safety selector allowing switching between standard disconnector mode and a forced reset sequence. |
Trademark & Unfair Competition Infringement
Trademark Infringement & Unfair Competition: Highlights the unauthorized use of the “FRT” trademark and its registered variants. The Defendants are accused of marketing trigger items using Rare Breed’s exact branding to capitalize on its market footprint and widespread consumer recognition.
False Designation of Origin: Asserts that the retail marketing tactics are highly likely to confuse or deceive consumers into falsely believing that the inventory sold by Tactical Solutions Group originates from, is endorsed by, or is affiliated with Rare Breed Triggers.
Remedy & Relief Sought
The Plaintiffs claim severe, ongoing economic and reputational harm due to these unauthorized retail sales and deceptive branding practices. They are requesting that the federal court grant the following relief:
Injunctions: Both preliminary and permanent injunctions to immediately halt Tactical Solutions Group, LLC and its principals from manufacturing, importing, advertising, or selling the Super Safety kits, components, or any aftermarket components bearing the FRT marks.
Damages & Disgorgement: Full financial compensation for lost retail profits or reasonable royalties resulting from patent infringement, alongside the disgorgement of all profits pocketed from trademark violations.
Punitive Multipliers: Asking the court to treble (triple) the final calculated damages due to the “egregious and willful” nature of the patent and trademark infringement.
Legal Fees: A declaration that this constitutes an “exceptional case” under federal law, requiring the Defendants to pay all of the Plaintiffs’ attorneys’ fees, corrective advertising costs, and associated legal expenses.
