Unreported / Non-Citable
Background
ABC IP, LLC and Rare Breed Triggers, Inc. brought patent-infringement actions against manufacturers, importers, distributors, and resellers of products allegedly infringing their patented forced-reset-trigger technology. In April 2026, the Judicial Panel on Multidistrict Litigation transferred five cases to the Eastern District of Texas for coordinated or consolidated pretrial proceedings in MDL No. 3176, In re: Rare Breed Triggers Patent Litigation. More than 100 cases were later transferred into the MDL.
More than 30 defendants in 32 member actions, including Shooting Targets USA, LLC and Michael Joseph Speeney, moved to stay the claims against them pending final resolution of related infringement actions against the relevant manufacturers. They relied on the customer-suit exception and traditional stay factors, arguing that the manufacturer actions should proceed first.
The Court’s Holding
The court denied all 13 pending motions to stay. It explained that the customer-suit exception permits, but does not require, a court to stay patent claims against customers while claims against manufacturers are resolved. The governing considerations are efficiency and judicial economy.
Those considerations did not favor stays because the MDL itself was designed to coordinate the related litigation, eliminate duplicative discovery, prevent inconsistent pretrial rulings, and conserve resources. The court also found that the forum-shopping concerns underlying the customer-suit exception were absent. Rule 16.1 mechanisms—including consolidated pleadings and leadership counsel—could further streamline the litigation without staying the reseller cases and prolonging plaintiffs’ efforts to resolve their claims.
Key Takeaways
- The customer-suit exception is discretionary, even when patent suits against manufacturers and their customers proceed in parallel.
- An existing MDL may substantially weaken the efficiency rationale for staying customer or reseller actions.
- The court concluded that coordinated pleadings, leadership counsel, and other case-management tools could achieve efficiency without delaying the member actions.
Why It Matters
The decision keeps dozens of customer and reseller cases moving alongside the related manufacturer actions. It signals that defendants in a centralized patent MDL may have difficulty obtaining customer-suit stays when the MDL already addresses the risks of duplicative discovery and inconsistent pretrial rulings.