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. After the Judicial Panel on Multidistrict Litigation transferred five cases to the Eastern District of Texas in April 2026, more than 100 cases joined the coordinated proceeding known as In re: Rare Breed Triggers Patent Litigation.
More than thirty defendants in thirty-two member actions moved to stay the claims against them until related suits against the products’ manufacturers were finally resolved. They invoked the customer-suit exception and the traditional factors governing stays, arguing that the manufacturer actions should proceed first.
The Court’s Holding
The court denied all thirteen motions to stay. It explained that staying customer litigation in favor of manufacturer litigation is discretionary rather than automatic and that efficiency and judicial economy guide application of the customer-suit exception.
Those considerations did not favor stays here because the MDL was already designed to coordinate and streamline the related litigation. The court emphasized that centralization would reduce duplicative discovery, avoid inconsistent pretrial rulings on matters including claim construction, patent validity, and injunctive relief, and conserve resources. It also found that the forum-shopping concerns associated with a traditional first-to-file dispute were absent.
The court further noted that Federal Rule of Civil Procedure 16.1 permits consolidated pleadings, leadership appointments, and other case-management measures that can improve efficiency without pausing the customer cases and prolonging the plaintiffs’ litigation.
Key Takeaways
- The customer-suit exception does not require a court to stay patent claims against customers or resellers whenever parallel manufacturer litigation exists.
- Efficiency and judicial economy weighed against stays because the centralized MDL already provided mechanisms for coordinating the related cases.
- The court denied the pending stay motions across thirty-two member actions, allowing those cases to continue within the MDL.
Why It Matters
The ruling shows that MDL centralization can reduce the force of a request to suspend customer or reseller cases in favor of manufacturer suits. Where coordinated pretrial management already addresses duplication and inconsistent rulings, a court may conclude that separate stays would not advance efficiency.
The decision is limited to whether these member actions should be stayed; it does not resolve the underlying infringement, validity, or injunctive-relief issues.