In a major development in the ongoing legal disputes surrounding forced reset triggers (FRTs), a federal judge in Wyoming has denied a motion by Rare Breed Triggers and its affiliate, ABC IP, LLC, for a temporary restraining order (TRO) and preliminary injunction against competitor Peak Tactical, LLC (doing business as Partisan Triggers) and its owner, Nicholas Norton.
The ruling, issued on February 13, 2026, in the U.S. District Court for the District of Wyoming, allows Partisan Triggers to continue manufacturing and selling its Partisan Disruptor trigger while the patent infringement and false advertising lawsuit proceeds toward trial. The decision follows a February 4, 2026, in-person hearing at which both parties presented arguments and testimony.
Forced reset triggers are aftermarket devices designed for semi-automatic firearms, primarily AR-15-style rifles. They mechanically reset the trigger after each shot, enabling faster follow-up shots without requiring the shooter to fully release finger pressure, resulting in a rapid-fire capability while remaining classified as semi-automatic under federal law (at least post-2025 developments). Rare Breed’s flagship product, the FRT-15L3, sells for approximately $450, while the Disruptor is marketed at a lower price point, at approximately $299 through certain distributors.
Rare Breed, through ABC IP (which owns the patents) and Rare Breed Triggers, Inc. (the exclusive licensee and manufacturer), sued Peak Tactical in early 2026. The complaint alleges willful direct, contributory, and induced infringement of four patents: U.S. Patent Nos. 10,514,223; 11,724,003; 12,036,336; and 12,274,807. These patents cover FRT designs that are retrofittable to existing semi-automatic rifles. Plaintiffs also claimed false patent marking and false advertising under the Lanham Act, asserting that Partisan mislabels the Disruptor as an “assisted reset trigger” (rather than a forced reset trigger) and falsely claims it practices an older patent (U.S. Patent No. 9,146,067) held by a Partisan employee, Michael Stakes. That patent covers the Tac-Con 3MR trigger.
Rare Breed sought to enjoin Defendants from making, selling, or importing the Disruptor (or substantially identical products), and from making disputed public statements about its design and patent coverage.
In their motion, Plaintiffs argued a strong likelihood of success on the merits, citing ownership of the patents, the Disruptor’s alleged close resemblance to their FRT-15L3 (described as a “direct copy” with only minor cosmetic differences), and no substantial prior challenge to patent validity. They asserted irreparable harm from price erosion, loss of market share, reputational damage, and business losses, and that the balance of hardships favored them and that the public interest supports patent enforcement.
Defendants countered that the Disruptor does not meet key claim limitations of the asserted patents, supported by expert analysis. They highlighted that their ‘067 patent (an assisted reset design) predates Rare Breed’s patents and argued that the Disruptor practices the asserted claims in that patent, while suggesting that Rare Breed’s own products may infringe Peak Tactical’s patent. They contended that claim construction would be needed, criticized Plaintiffs’ infringement evidence as conclusory and lacking element-by-element detail, and disputed the false advertising claims by arguing that terms like “assisted reset,” “forced reset,” and “positive reset” describe similar mechanisms.
On irreparable harm, Defendants pointed to Plaintiffs’ delay in suing (months after the Disruptor hit the market) while pursuing other dealer lawsuits, suggesting any harm is compensable via money damages (lost profits, royalties, etc.). They warned that an injunction would devastate their small business, causing collapse, while Plaintiffs’ harm remains monetary. They also argued that the public interest favors competition, not early shutdowns, and that any injunction would require a substantial bond.
The court applied the four-factor test for preliminary injunctive relief (likelihood of success, irreparable harm, balance of equities, public interest), finding that all weighed against granting the TRO or injunction. Irreparable harm was deemed insufficiently shown, given the delay and availability of damages. The court treated the TRO and preliminary injunction requests under the same standards, emphasizing injunctive relief as an “extraordinary remedy” not awarded lightly.
This ruling comes amid a broader context for FRTs. In 2025, following legal challenges and a Supreme Court decision in a related bump stock case, the Department of Justice under the Trump administration settled litigation with Rare Breed, allowing resumption of FRT sales under certain conditions, including Rare Breed’s commitment to enforce its patents aggressively (and not develop pistol versions). That settlement has shaped recent private enforcement actions, with Rare Breed pursuing multiple infringement suits against competitors.
The denial in Wyoming marks a setback for Rare Breed’s efforts to quickly halt a lower-priced rival, potentially preserving market competition in the FRT space. The case remains ongoing, with potential for further discovery, claim construction, and trial on the merits. Neither side has indicated immediate plans for appeal of the injunction denial, though preliminary injunction rulings are appealable.
Industry observers note this highlights tensions between patent holders seeking to protect innovations (especially post-ATF settlement obligations) and competitors offering arguably prior-art-based or differently designed alternatives at lower prices. The outcome could influence other pending FRT-related patent disputes.
ATF Intervenes in Forced Reset Trigger Patent Lawsuit for “Public Safety”
DOJ Filing on Forced Reset Triggers Contradicts Pledges and Complicates Midterms
About John Crump
Mr. Crump is an NRA instructor and a constitutional activist. John has written about firearms, interviewed people from all walks of life, and on the Constitution. John lives in Northern Virginia with his wife and sons, follow him on X at @crumpyss, or at www.crumpy.com.
