Timothy S. Bero is a mechanical engineer and owner of TNW Firearms, Inc. of Vernonia, Oregon, which specializes in converting “vintage” fully automatic machine guns into semiautomatic weapons that comply with state and federal restrictions on automatic firearms. As part of his conversion process, Mr. Bero designs new firing mechanisms, also known as “receivers,” for various machine guns. Mr. Bero patented one of his designs in U.S. Patent No. 6,543,169, which claims a replacement receiver for a fully automatic .50 caliber machine gun. TNW is the exclusive licensee of the '169 patent and sells the patented replacement receivers for M2HB, M3HB, M3AC, and MG 34 firearms.

Tactical Manufacturing, Inc. (TMI) of Warren, Oregon is an alleged administratively dissolved Oregon corporation, but according to the complaint (pdf) TMI continues to function as an operating entity. Mr. Bero and TNW allege that TMI directly infringes the '169 patent by selling the patented replacement receivers. TNW seeks injunctive relief, damages, and attorneys’ fees and costs for alleged sales of the patented replacement receivers.