Unreported / Non-Citable
Background
ABC IP, LLC and Rare Breed Triggers, Inc. sought a consolidated preliminary injunction against defendants in multidistrict patent litigation involving alleged infringement of trigger-related patents. Several defendant groups, including Superior Firearms of Texas, moved to stay and enlarge briefing and discovery deadlines, require a structured conferral process, and hold a status conference.
Defendants also asked the court to stay the preliminary-injunction proceedings pending Federal Circuit appeals arising from separate Partisan and Hoffman cases. In addition, they sought to hold the consolidated preliminary-injunction motion in abeyance until the court resolved motions for leave to amend the complaints to assert infringement of U.S. Patent No. 12,626,403.
The Court’s Holding
The court denied as moot the request to enlarge deadlines and impose a 21-day conferral period because it had already authorized expedited discovery and established a preliminary-injunction briefing schedule. It likewise denied as moot the requested stay based on the Partisan appeal because the Federal Circuit had already affirmed the denial of injunctive relief in that case.
The court denied the requested stay based on the still-pending Hoffman appeal, concluding that the Federal Circuit’s decision there would not substantially affect the present proceedings because the consolidated motion concerned different defendants and a different evidentiary record. Finally, the court denied the abeyance motion as moot because it had already granted leave to amend the underlying complaints to add claims involving the ’403 patent.
Key Takeaways
- Prior scheduling and discovery orders rendered defendants’ requests to postpone preliminary-injunction deadlines moot.
- An appeal involving the same patentee and similar alleged harm did not justify a stay where the requested injunction concerned different parties and a different evidentiary record.
- The court’s authorization of amended complaints eliminated the stated basis for holding the consolidated preliminary-injunction motion in abeyance.
Why It Matters
The decision allows the consolidated preliminary-injunction proceedings to continue without waiting for the Hoffman appeal. It also underscores that preliminary-injunction determinations are tied to the parties and record before the court, even when related litigation presents overlapping patent and competitive-harm issues.
The parties must meet and confer about any remaining procedural disputes before the October 15, 2026 case-management conference and may raise unresolved issues at that conference.