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  #1  
Old 05-18-2018, 12:26 PM
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Default Registration Failed for PRS stock

"Thank you for submitting your application. Based on the photos you provided, there is an additional characteristic shown on your firearm that was not marked on the application. The Department considers your stock to be Telescoping, although it may adjust in length only slightly. Please refer to California Code of Regulations, title 11, section 5471(oo) for more information: https://oag.ca.gov/sites/all/files/a...let-button.pdf
The information requested should be submitted by logging into the CFARS application https://cfars.doj.ca.gov and selecting "My Transaction History". If you have any questions, please use the Report an Issue feature in the CFARS application."

I will have to tick the box to comply due to time constraints, but how can we bring this to the courts to show them that a PRS stock does not telescope in any way. Only the buttplate can adjust and a buttplate is not a stock....

sub section “oo” states the buffer tube acts as a fixed portion of the stock and the adjustment telescopes off that. The prs is fixed in length and the adjustment occurs external to the fixed buffer tube.

Quote:
Originally Posted by Chapter 39 Assault Weapons and Large-Capacity Magazines
(oo) “Stock, telescoping” means a stock which is shortened or lengthened by allowing one
section to telescope into another portion. On AR-15 style firearms, the buffer tube or
receiver extension acts as the fixed part of the stock on which the telescoping butt stock
slides or telescopes.
PRS clearly does not slide or telescope when used on an AR-15 style firearm. This is certainly an overreach and contradiction to the laws passed, as well as an unjustified rejection of registration.

I well be submitting an issue through CFARS when I return from camping.

Last edited by Justintoxicated; 05-18-2018 at 12:34 PM..
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  #2  
Old 05-18-2018, 12:47 PM
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Well that is frustrating. The people reviewing these applications have no clue. One thread a while back said the reviewer called his Magpul MOE stock a thumbhole stock (because of the big triangular shaped hole).
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Old 05-18-2018, 12:50 PM
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You are registering an AW?

From a grand scheme POV for you, check the box and move on, the rest of the rifle makes it an AW anyway. But it does set precedence and reinforces the incorrect (IMHO) DOJ view of what is "telescoping".
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  #4  
Old 05-18-2018, 12:51 PM
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wow, that is stupid.

whatever. still going to use my prs on my featureless rifle.
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Because -ohmigosh- they can add their opinions, too?
Proof we can all comment on whatever we want if it's at all related to the topic at hand!
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  #5  
Old 05-19-2018, 6:20 PM
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This issue has been noted a couple times in the main AW Reg Guide and another thread, so I submitted mine "correctly" by marking it as telescoping. (Though still waiting on my approval letter.)

Of course this is b.s. from reading all of the laws & regulations. But I imagine the best way to challenge this is if someone removes all other features & tries to deregister a rifle with only a PRS. Hopefully someone is already planning to do this.
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  #6  
Old 05-20-2018, 1:49 PM
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So if someone checks the box that this is a telescoping stock, then if they have another featureless rifle with a PRS stock, wouldn't that kind of screw them later should it be said they have an unregistered assault rifle?
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  #7  
Old 05-20-2018, 3:15 PM
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Originally Posted by Justintoxicated View Post
So if someone checks the box that this is a telescoping stock, then if they have another featureless rifle with a PRS stock, wouldn't that kind of screw them later should it be said they have an unregistered assault rifle?
Thats the way I see it but that's just my view. Still, if you go featureless, why not just buy a solid fixed stock? They don't cost much and there is no questionable area of whether it is telescoping or not.
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  #8  
Old 05-20-2018, 3:59 PM
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Originally Posted by shooter556 View Post
Thats the way I see it but that's just my view. Still, if you go featureless, why not just buy a solid fixed stock? They don't cost much and there is no questionable area of whether it is telescoping or not.
Because a PRS stock has benefits that an A2 or Magpul Rifle Stock doesn't? If you are into precision shooting, you want to be able to easily adjust comb height and LOP.

I sold my PRS for precisely this reason--not worth a self-promoting DA trying to make an example out of me.

Justintoxicated--contact Michel and Associates and see if CRPA is interested in adding you as a plaintiff to the Villanueva litigation in Fresno. I doubt you have standing because there's no actual harm to you (as you said, you can just check the box and proceed to register the AW), but maybe (hopefully) I'm wrong.

Perhaps a better plaintiff would be somebody who wants to go featureless with a PRS stock and seeks a declaratory judgment that such a stock does not make a weapon an AW. That person would obviously have to keep the upper and lower separate until there's legal clarification on this.
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  #9  
Old 05-20-2018, 3:59 PM
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People reviewing the applications are not very savvy regarding firearms.
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  #10  
Old 05-22-2018, 8:27 AM
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Quote:
Originally Posted by Califpatriot View Post
Because a PRS stock has benefits that an A2 or Magpul Rifle Stock doesn't? If you are into precision shooting, you want to be able to easily adjust comb height and LOP.

I sold my PRS for precisely this reason--not worth a self-promoting DA trying to make an example out of me.

Justintoxicated--contact Michel and Associates and see if CRPA is interested in adding you as a plaintiff to the Villanueva litigation in Fresno. I doubt you have standing because there's no actual harm to you (as you said, you can just check the box and proceed to register the AW), but maybe (hopefully) I'm wrong.

Perhaps a better plaintiff would be somebody who wants to go featureless with a PRS stock and seeks a declaratory judgment that such a stock does not make a weapon an AW. That person would obviously have to keep the upper and lower separate until there's legal clarification on this.
The issue is the law clearly and specifically defines the meaning of telescoping for AR-15 style rifles. DOJ arguing this and telling people to lawyer up is complete garbage.

I checked the box but submitted an issue, quoting the specification and stating why PRS does not fit the description.
Today I received this notice and I have no idea what it means.

Quote:
The California Department of Justice has received your electronic AB 1135/SB 880 Assault Weapon Registration; however, it cannot be processed for the following reason(s):
As per manage issues comment, this application has been marked incomplete so the applicant can make corrections on this application.
N/M I found a message in CFARS.

Quote:
according to California Code of Regulations, title 11, section 5471(oo), "Stock, telescoping" means a stock which is shortened or lengthened by allowing one section to telescope into another portion. Please make the necessary updates and resubmit your application for further processing. Thank you.
Since I checked the box are they saying they want me to uncheck the box now?

my response...
Quote:
Hello, I'm not sure what changes you want me to make. The second part of section oo clarifies the first part and is specific for AR-15 style rifles. The law written needs to be read in it's entirety. "On AR-15 style firearms, the buffer tube or receiver extension acts as the fixed part of the stock on which the telescoping butt stock slides or telescopes". PRS stocks do not do this so marking it as such would be incorrect. Only the butt-plate has adjustment and does not move on the buffer tube
Sounds like I need to find an attorney.

it is difficult to type out an argument in 500 characters....

Last edited by Justintoxicated; 05-22-2018 at 1:30 PM..
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  #11  
Old 05-22-2018, 11:10 AM
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AFAIK...

Back in 2013, the Magpul PRS was discussed.

Because "telecoping" is not defined by CA laws/regulations, the length of pull of adjustments on the PRS could be determined to make the stock a "telescoping stock".

It was then recommend (by CRPA & FPC lawyers) that in order to be CA legal, the Magpul PRS should only be utilized on manually operated rifles or rimfire rifles or semi-auto centerfire with fixed magazine.
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Last edited by Quiet; 05-22-2018 at 12:20 PM..
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  #12  
Old 05-23-2018, 8:43 AM
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This technically makes the Magpul fixed carbine stock illegal if you add or remove the PRS extended rubber butt pad. That makes the LOP "adjustable" too.

Guess I'm a featureless felon now?
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  #13  
Old 05-23-2018, 9:00 AM
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Originally Posted by Jimi Jah View Post
This technically makes the Magpul fixed carbine stock illegal if you add or remove the PRS extended rubber butt pad. That makes the LOP "adjustable" too.

Guess I'm a featureless felon now?
Adding or removing an extension piece is not the same as telescoping. They've defined telescoping as:

Quote:
(oo) “Stock, telescoping” means a stock which is shortened or lengthened by allowing one section to telescope into another portion. On AR-15 style firearms, the buffer tube or receiver extension acts as the fixed part of the stock on which the telescoping butt stock slides or telescopes.
While I don't agree with DOJ that the PRS adjustable buttpad fits into that definition, I can kinda sorta see why they think it does.

But adding or removing a buttpad spacer most definitely does not fit that definition.

DOJ has been pretty consistent with calling the PRS stock a telescoping stock. I've seen many applications kicked back for this reason, to the point where I added a note in the registration guide a few months ago that says "DOJ considers PRS stocks (and similar) to be telescoping stocks."

Last edited by cockedandglocked; 05-23-2018 at 9:03 AM..
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  #14  
Old 05-23-2018, 4:12 PM
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Quote:
Originally Posted by Justintoxicated View Post
"Thank you for submitting your application. Based on the photos you provided, there is an additional characteristic shown on your firearm that was not marked on the application. The Department considers your stock to be Telescoping, although it may adjust in length only slightly. Please refer to California Code of Regulations, title 11, section 5471(oo) for more information: https://oag.ca.gov/sites/all/files/a...let-button.pdf
The information requested should be submitted by logging into the CFARS application https://cfars.doj.ca.gov and selecting "My Transaction History". If you have any questions, please use the Report an Issue feature in the CFARS application."

I will have to tick the box to comply due to time constraints, but how can we bring this to the courts to show them that a PRS stock does not telescope in any way. Only the buttplate can adjust and a buttplate is not a stock....

sub section “oo” states the buffer tube acts as a fixed portion of the stock and the adjustment telescopes off that. The prs is fixed in length and the adjustment occurs external to the fixed buffer tube.



PRS clearly does not slide or telescope when used on an AR-15 style firearm. This is certainly an overreach and contradiction to the laws passed, as well as an unjustified rejection of registration.

I well be submitting an issue through CFARS when I return from camping.
I’ve been saying this since SB880 passed. DOJ is going to rule A PRS stock telescopes ( just like you can’t take off your BB). Doesn’t matter if it’s a 1/4” or 4”. DOJ just makes up regs as it pleases and the there is no redress in the crooked court system.
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Last edited by Blade Gunner; 05-23-2018 at 4:21 PM..
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  #15  
Old 05-23-2018, 4:56 PM
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I guess I will join the paranoid gun owners on this forum and add a set screw to the stock so that it can still be adjusted. Just have to remove the upper first so stupid and pointless.

I still strongly disagree with whoever is approving my application. The second sentence specifies what qualifies for AR-15 style rifles and the PRS does not in any interpretation possibly meet these requirements.

DOJ's argument is that if you don't like their absolutely wrong interpretation get a lawyer.... Next thing you know they will start making claims that Ice is hot and Fire is cold, walking is running etc.
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Old 05-23-2018, 5:09 PM
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Quote:
Originally Posted by Justintoxicated View Post
I guess I will join the paranoid gun owners on this forum and add a set screw to the stock so that it can still be adjusted. Just have to remove the upper first so stupid and pointless.

I still strongly disagree with whoever is approving my application. The second sentence specifies what qualifies for AR-15 style rifles and the PRS does not in any interpretation possibly meet these requirements.

DOJ's argument is that if you don't like their absolutely wrong interpretation get a lawyer.... Next thing you know they will start making claims that Ice is hot and Fire is cold, walking is running etc.
Or don't add a setscrew and just check the box for telescoping stock. At this point, when it comes to this trivial crap about DOJ arguing what is and isn't a feature, it's maybe best to just play along with their dumb game so you can be done with it. You can add or remove whatever AW features after it's registered anyways, so it's really not worth arguing with them too much.
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Old 05-23-2018, 5:48 PM
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Quote:
Originally Posted by cockedandglocked View Post
Or don't add a setscrew and just check the box for telescoping stock. At this point, when it comes to this trivial crap about DOJ arguing what is and isn't a feature, it's maybe best to just play along with their dumb game so you can be done with it. You can add or remove whatever AW features after it's registered anyways, so it's really not worth arguing with them too much.
For that rifle sure, for featureless builds, checking that box is admitting it is a telescoping stock.

I think DOJ is interpreting any adjustable stock to be telescoping/folding/sliding and that is simply not true.
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Old 05-24-2018, 8:47 AM
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They can interpret anything any way they want and they can change their position at any time.
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Old 05-24-2018, 8:53 AM
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Quote:
Originally Posted by Justintoxicated View Post
For that rifle sure, for featureless builds, checking that box is admitting it is a telescoping stock.
For featureless builds, there's no box to check, because you wouldn't be submitting it for AW registration.

Since he was presented with a box to check, it's a fair assumption that's it's an AW that he is registering, and therefore it's perfectly legal to have a telescoping stock, which is why I recommended just playing their silly game and checking the box.

It's like if you have a muzzle brake on your AW, and DOJ is insisting that it looks like a flash hider and you need to check that box... there's really not any point in arguing with them about it, just check the box so everyone can move on.

Last edited by cockedandglocked; 05-24-2018 at 8:58 AM..
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Old 05-24-2018, 9:43 AM
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Quote:
Originally Posted by cockedandglocked View Post
For featureless builds, there's no box to check, because you wouldn't be submitting it for AW registration.

Since he was presented with a box to check, it's a fair assumption that's it's an AW that he is registering, and therefore it's perfectly legal to have a telescoping stock, which is why I recommended just playing their silly game and checking the box.

It's like if you have a muzzle brake on your AW, and DOJ is insisting that it looks like a flash hider and you need to check that box... there's really not any point in arguing with them about it, just check the box so everyone can move on.
I think his concern is that if he registers one rifle with a PRS that's marked as a telescoping stock and has another featureless rifle with a PRS stock, he is basically admitting that both rifles have telescoping stocks.
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Old 05-24-2018, 10:04 AM
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Originally Posted by sirsloth View Post
I think his concern is that if he registers one rifle with a PRS that's marked as a telescoping stock and has another featureless rifle with a PRS stock, he is basically admitting that both rifles have telescoping stocks.
this^
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Old 05-24-2018, 10:33 AM
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Quote:
Originally Posted by cockedandglocked View Post
It's like if you have a muzzle brake on your AW, and DOJ is insisting that it looks like a flash hider and you need to check that box... there's really not any point in arguing with them about it, just check the box so everyone can move on.

So just check off Flash Hider every time even if you have Brake(s)?


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Old 05-24-2018, 10:43 AM
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Originally Posted by Justintoxicated View Post
this^
My bad, reading fail on my part

Quote:
Originally Posted by Maltese Falcon View Post
So just check off Flash Hider every time even if you have Brake(s)?
No, check the box if it's a flash hider, don't check it if it's a muzzle brake.

What I meant was, if DOJ starts an argument about what kind of muzzle device it is, it's not worth engaging with them. Just change the checkbox to whatever they tell you to change it to and move on, because it's really not relevant in the grand scheme of things, since we can change what "features" our guns have, whenever we want, after registration.
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Old 06-04-2018, 9:06 AM
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I got my registration on this weekend and one of my builds that was approved has a Magpul PRS stock. I checked the boxes for pistol grip and flash hider so those features are covered. However, I did not discover the issue with the PRS stock until after I submitted my application. DOJ approved it anyway. I need to figure out if I'm compliant now or not. If I can add/change features after registration is granted then I should be OK. I'm just not sure at this point.
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Old 06-04-2018, 9:11 AM
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I got my registration on this weekend and one of my builds that was approved has a Magpul PRS stock. I checked the boxes for pistol grip and flash hider so those features are covered. However, I did not discover the issue with the PRS stock until after I submitted my application. DOJ approved it anyway. I need to figure out if I'm compliant now or not. If I can add/change features after registration is granted then I should be OK. I'm just not sure at this point.
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Old 06-04-2018, 9:29 AM
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It's generally understood that there are no regulations prohibiting configuration changes onto a BBAW post-registration, aside from the regulations that the DOJ concocted (not specifically in the legislation) about never being able to remove the gun from a bullet-button state. So you can change out the stock as you wish once it's registered.
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Old 06-04-2018, 11:32 AM
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Ya you're fine, no compliance issues, because you're allowed to have a collapsing stock (or other evil features) on a RAW regardless of what boxes you checked. So it doesn't matter what the DOJ employee considered your PRS stock, as long as it's registered that's the important thing.

There's a common myth (especially spread at gun stores) that you're forever "locked into" whatever features you marked on your app, but that is simply not true. The only feature you can't change is replacing the bullet button with a normal button, or making the gun into a configuration that breaks other laws (SBR, sound suppressors, etc)

Last edited by cockedandglocked; 06-04-2018 at 11:36 AM..
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Old 06-04-2018, 4:20 PM
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I'm curious, if one submits their AW registration online and it bounces back after the deadline are they still able to resubmit their registration?
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Old 06-04-2018, 4:31 PM
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my rifles all have V6 Gamma brakes but the card said flash hider as well so I marked them all flash hiders....will they freak about those too?
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Old 06-04-2018, 6:16 PM
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I'm curious, if one submits their AW registration online and it bounces back after the deadline are they still able to resubmit their registration?
I've been wondering this as well
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Old 06-04-2018, 6:23 PM
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Originally Posted by secondwind View Post
I'm curious, if one submits their AW registration online and it bounces back after the deadline are they still able to resubmit their registration?
Nobody knows for sure, but most signs point to the likelihood that they'll honor applications that are submitted before the deadline, even if they request corrections after the deadline, as long as you make the corrections within 30 days. If you don't fix it within 30 days, they'll cancel your app and you'll be up a creek.

It's very unlikely that they'd outright reject your app, unless you tried registering something you weren't supposed to. Rather, they mark your app as "incomplete" and send you one email (and ONLY one email, so look for it) asking you to make whatever change they are wanting you to make.

In any case, if you don't have a letter in-hand yet on June 30th, you NEED to disassemble your rifles while you wait for your letter, since that is the last day of the possession grace period.
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Old 06-09-2018, 8:33 PM
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Quote:
Originally Posted by cockedandglocked View Post
Or don't add a setscrew and just check the box for telescoping stock. At this point, when it comes to this trivial crap about DOJ arguing what is and isn't a feature, it's maybe best to just play along with their dumb game so you can be done with it. You can add or remove whatever AW features after it's registered anyways, so it's really not worth arguing with them too much.


Agree. I got comments back for all kinds of inconsequential stuff (interchangeable barrels, foregrips, flash-hiders, collapsible buttstocks, etc). My comment for resubmission was always prefaced with “Per your directive I have changed my application as noted” The more you argue with them, the more attention you call to yourself.


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Old 06-09-2018, 8:44 PM
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Quote:
Originally Posted by sirsloth View Post
I think his concern is that if he registers one rifle with a PRS that's marked as a telescoping stock and has another featureless rifle with a PRS stock, he is basically admitting that both rifles have telescoping stocks.


That is a conundrum. I pinned the length of pull on all my featureless AR with PRS. It’s only a PIA if you transition from bench to prone. I don’t want to get in a losing expensive debate with some LE or DA.


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Old 06-10-2018, 12:13 PM
WHITE MAMBA WHITE MAMBA is offline
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Originally Posted by cockedandglocked View Post
Nobody knows for sure, but most signs point to the likelihood that they'll honor applications that are submitted before the deadline, even if they request corrections after the deadline, as long as you make the corrections within 30 days. If you don't fix it within 30 days, they'll cancel your app and you'll be up a creek.

It's very unlikely that they'd outright reject your app, unless you tried registering something you weren't supposed to. Rather, they mark your app as "incomplete" and send you one email (and ONLY one email, so look for it) asking you to make whatever change they are wanting you to make.

In any case, if you don't have a letter in-hand yet on June 30th, you NEED to disassemble your rifles while you wait for your letter, since that is the last day of the possession grace period.

I was told yes. Doj said that as long as I'm in the system I'm good to go as far as making changes to the paperwork.
They are backed up about a month currently
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Old 06-11-2018, 5:42 PM
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Originally Posted by Maltese Falcon View Post
So just check off Flash Hider every time even if you have Brake(s)?


.
This is where the problems lie when attempting interpret features be it a telescoping stock or a flash hider. Many people will be quite disappointed when there muzzle brake with no top ports is determined to perceptibly reduce muzzle flash from the shooters field of vision, or their stock adjusts length of pull even just a little and is determined to be telescoping.
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Old 06-13-2018, 5:03 AM
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There was no issue with my PRS although I tightened up all the adjustments before submitting the pictures.
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Old 06-13-2018, 8:13 AM
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Can it be argued that the mechanical function of the Magpul PRS stock is non telescoping when adjusting length of pull? The adjusting knob works on a threaded screw that is affixed to the buttplate. So in essence nothing is sliding over the buffer tube as outlined above in other posts
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Oh for ****s sake, now there are two of them.This is the type of **** anti's point to when they want to make us all look crazy.
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Old 06-13-2018, 9:13 AM
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Default Registration Failed for PRS stock

Quote:
Originally Posted by bomb_on_bus View Post
Can it be argued that the mechanical function of the Magpul PRS stock is non telescoping when adjusting length of pull? The adjusting knob works on a threaded screw that is affixed to the buttplate. So in essence nothing is sliding over the buffer tube as outlined above in other posts


https://leginfo.legislature.ca.gov/f...5.&lawCode=PEN

As written the regs just say telescoping stock. It makes no distinction if the stock 1” or 6”. It makes no distinction between telescoping over a buffer tube or not.
Examples: A SCAR or an ACR do not have buffer tubes but have telescoping stocks. Unless you can find a specific exemption or case law for PRS type of stocks, the safe bet is to assume they meet the definition of telescoping.



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