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In 2008, he filed a lawsuit against the ATF claiming the new ruling was arbitrary and capricious and violated his right to due process, an argument rejected by district and appellate courts.

“An ATF letter opinion is worthless,” he said. “It is not law, and it can be changed at the whim of a bureaucrat.”

Larry Keane, general counsel for the National Shooting Sports Foundation, said letter rulings can be “all over the map,” particularly on the point in the manufacturing process when a piece of metal becomes a firearm subject to federal law.

He said the rulings are determined on “an ad hoc basis” and that it is nearly impossible to comply with the law with no clear definition from the ATF and varying interpretations from the courts.

“It is unfair for ATF to hold individuals to a standard that they cannot articulate themselves,” he said.