Yes, I think it's 100% unwinnable. What you'd effectively be asking the court to do is re-open registration for a previously banned AR configuration and that would be the framework for any interpretation the court would do. I think you'd need a much more compelling textual basis than the "well it's defined as an AW now so it doesn't matter if it has a BB or a standard mag release" argument, again IMO. DOJ is empowered to make regulations to implement the bullet button firearm ban and the " no registration of firearms meeting definition of AW under prior law", "must provide digital pics of bullet button release", and "can't change release device" regulations are all consistent with the legislative purpose of banning and allowing a time-limited registration period for bullet button firearms. Can you make an argument that you meet the requirement for registration that you lawfully possessed the firearm in a BB configuration through 12/31/16, and once defined as an AW the release mechanism BB vs. standard is irrelevant? Sure. But that would be your interpretation competing against DOJ's interpretation, which the statute authorizes it to make via regulation, and i think you would lose that one.
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MERGED THREADS "Bullet Button Assault Weapon" Regs
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I did a rough OCR conversion in Acrobat to make the text searchable and cut-and-pasteable.
Please confirm with the original - but beats typing it out.
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What if it's already registered as an AW? How could one be charged with manufacturing?Comment
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I don't understand why they made such an allowance for featureless. I get the evil features they covet, but with as much latitude as they took on this release, why stop where they did with such an obvious work around?CA Ex-Pat
US Navy Veteran
NRA Life Member
Springfield Armory & Smith&Wesson & Remington & Henry & Marlin
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"Why does anyone need an AR-15?
You mean you don't know? So what kind of reporter are you? It's easy! It's a great friggen gun!" - Alan Korwin, 2015Comment
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I just got a email from fpc saying that the doj says even if we register as AW we still cant remove the bullet button anyone else get this email or know whats going on?Comment
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It does say that they have to be complete when registered. But if not registered at the same time, why not. Just an extra $15. How about the situation where you have 4 complete lowers and 4 complete uppers. Does anyone see anything in the regulations that would prevent one from registering 16 different combinations?Comment
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Ya... without looking at the bolt, you can't tell the difference on the exterior between my Stag 22lr dedicated upper and my Armalite DEF-15.Handguards are cheap, $5 for a std carbine set, and Krylon is cheap too. $10 or less to make an upper look 'different' - not that you'd need to. A standard PSA complete upper from a basic rifle kit looks like 100,000 others. They're going to get plenty of 'same' upper photos, from thousands of people.- Rich

Originally posted by dantoddA just government will not be overthrown by force or violence because the people have no incentive to overthrow a just government. If a small minority of people attempt such an insurrection to grab power and enslave the people, the RKBA of the whole is our insurance against their success.Comment
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Thank you for this. You win one internet.I did a rough OCR conversion in Acrobat to make the text searchable and cut-and-pasteable.
Please confirm with the original - but beats typing it out.
https://dl.dropboxusercontent.com/u/...AINST-ORIG.pdfComment
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Yup. Specifically says mag release can't be changed once registered, and has to be registered with BB attached.Comment
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I think that would entail an outright ban on all semi auto rifles, I doubt it would hold up in any court including CA.
This is funny.
After a deranged 20-year-old brought unthinkable evil to Connecticut’s Sandy Hook Elementary in December 2012, both Connecticut and New York banned the sale of semiautomatic firearms they deem to be “assault weapons” and required owners of these guns to register them with the state. When the deadline for gun owners to [...]Comment
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CA Ex-Pat
US Navy Veteran
NRA Life Member
Springfield Armory & Smith&Wesson & Remington & Henry & Marlin
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"Why does anyone need an AR-15?
You mean you don't know? So what kind of reporter are you? It's easy! It's a great friggen gun!" - Alan Korwin, 2015Comment
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What if they demand receipts for the uppers shown in the photos before they approve your registration?Handguards are cheap, $5 for a std carbine set, and Krylon is cheap too. $10 or less to make an upper look 'different' - not that you'd need to. A standard PSA complete upper from a basic rifle kit looks like 100,000 others. They're going to get plenty of 'same' upper photos, from thousands of people.Comment
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