Unreported / Non-Citable
Background
ABC IP, LLC and Rare Breed Triggers, Inc. sought a consolidated preliminary injunction against defendants in multidistrict patent litigation involving firearm triggers. Various defendant groups filed motions seeking to stay and extend deadlines associated with the preliminary-injunction filings, require a structured conferral process, and obtain a status conference.
The defendants also asked the court to stay the preliminary-injunction proceedings pending Federal Circuit appeals arising from the Partisan and Hoffman cases. Separately, they sought to hold the preliminary-injunction motion in abeyance until the court resolved motions for leave to amend the complaints in the underlying actions to add infringement allegations concerning U.S. Patent No. 12,626,403.
The Court’s Holding
The court denied as moot the requested extensions, discovery-related relief, and structured conferral period because it had already authorized expedited discovery and established a preliminary-injunction briefing schedule. It directed the parties to meet and confer before the October 15, 2026 case-management conference and to raise any unresolved procedural issues there.
The court denied the requested appellate stay. The request concerning Partisan was moot because the Federal Circuit had affirmed the denial of injunctive relief in that case. The court declined to await Hoffman because that appeal involved different parties and a different evidentiary record and therefore would not substantially affect the preliminary-injunction issues before it. Finally, the court denied the abeyance motion as moot because it had already granted leave to amend the thirteen underlying complaints to assert infringement of the ’403 patent.
Key Takeaways
- The consolidated preliminary-injunction proceedings will continue under the court’s existing discovery and briefing schedule.
- An appellate ruling concerning another defendant and another evidentiary record did not justify staying the requested injunctions in these actions.
- Earlier case-management developments rendered the defendants’ deadline-extension, conferral, and patent-pleading objections moot.
Why It Matters
The ruling keeps the MDL’s preliminary-injunction process moving despite related Federal Circuit proceedings. It also underscores that preliminary-injunction determinations are tied to the parties and evidentiary record before the court, so an appeal involving the same patent owner and similar alleged harm will not necessarily warrant a stay.