Yes I believe it would. The Fed's definition of lock
(B) would certainly seem to apply here. Just don't forget the safe affidavit for CA.
(34) The term “secure gun storage or safety device” means—
(A) a device that, when installed on a firearm, is designed to
prevent the firearm from being operated without first
deactivating the device;
(B) a device incorporated into the design of the firearm that is
designed to prevent the operation of the firearm by anyone not
having access to the device; or
(C) a safe, gun safe, gun case, lock box, or other device
that is designed to be or can be used to store a firearm and
that is designed to be unlocked only by means of a key, a
combination, or other similar means.
(A) a device that, when installed on a firearm, is designed to
prevent the firearm from being operated without first
deactivating the device;
(B) a device incorporated into the design of the firearm that is
designed to prevent the operation of the firearm by anyone not
having access to the device; or
(C) a safe, gun safe, gun case, lock box, or other device
that is designed to be or can be used to store a firearm and
that is designed to be unlocked only by means of a key, a
combination, or other similar means.






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