ABC IP, LLC and Rare Breed Triggers, Inc. v. Argent Wolfz LLC et al
Case Overview
- Case Name: ABC IP, LLC and Rare Breed Triggers, Inc. v. Argent Wolfz LLC et al.
- Court: U.S. District Court for the District of Arizona (Phoenix Division)
- Case Number: 2:26-cv-05016-DMF
- Filing Date: July 17, 2026
- Plaintiffs: ABC IP, LLC and Rare Breed Triggers, Inc.
- Defendants: Argent Wolfz LLC (d/b/a T91 Tactical, Retro Motif, IBOR-USA); Sean Tsao; and Carrie Davis Tsao
- Nature of Action: Civil lawsuit alleging direct, contributory, and induced patent infringement with a demand for a jury trial.
Executive Summary
Plaintiffs ABC IP, LLC (the patent owner) and Rare Breed Triggers, Inc. (the exclusive licensee) have filed a multi-count patent infringement lawsuit against Arizona-based firearms component distributor Argent Wolfz LLC (doing business as T91 Tactical, Retro Motif, and IBOR-USA) along with its corporate owners, Sean Tsao and Carrie Davis Tsao. The federal complaint alleges that the Defendants are importing massive quantities of unauthorized conversion components from Taiwan to market, offer for sale, and sell online—specifically the (3-Position) “Super Safety” system (sold via argentwolfz.com).
Plaintiffs contend that these imported products directly infringe upon five utility patents within their intellectual property portfolio protecting forced reset trigger (FRT) firearm technology. Because the Defendants reportedly continued commercial distribution and marketing of these systems despite documented notice of the relevant patent protections, the Plaintiffs are charging them with willful infringement, exposing them to treble 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 Argent Wolfz LLC’s product offerings (sold via argentwolfz.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 | Safety mechanism for a firearm employing a multi-recess cam selector configured to transition between standard, active reset, and safe positions. |
| 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 the physical interaction profiles between hammer hooks, trigger members, and safety selectors. |
Indirect and Contributory Infringement
- Inducing Infringement: The suit highlights that the Defendants take active steps to induce infringement by marketing, advertising, promoting, and instructing customers on how to install and operate the Super Safety components within standard AR-15 fire control groups.
- Contributory Infringement: Asserts that key imported components distributed by the Defendants—such as standalone selector cams and linkage levers—are custom-engineered solely for use in an infringing fire control configuration and possess no substantial, non-infringing application.
Remedy & Relief Sought
The Plaintiffs claim ongoing, severe financial and market share harm due to these unauthorized sales and foreign import operations. They are requesting that the federal court grant the following relief:
- Injunctions: Both preliminary and permanent injunctions to immediately halt Argent Wolfz LLC, Sean Tsao, Carrie Davis Tsao, and their corporate DBAs from importing, manufacturing, advertising, or selling the Super Safety kits or matching aftermarket components.
- Damages: Full financial compensation adequate to remedy the infringement, calculated as lost retail profits or a reasonable royalty, alongside pre- and post-judgment interest.
- Punitive Multipliers: Asking the court to treble (triple) the total assessed compensatory damages under 35 U.S.C. § 284 due to the “egregious and willful” nature of the patent violations.
- Legal Fees: A declaration designating this lawsuit as an “exceptional case” under federal statute (35 U.S.C. § 285), requiring the Defendants to pay all of the Plaintiffs’ reasonable attorneys’ fees and litigation expenses.
