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EXPERT REPORT OF DAN BEDELL

MAY 5, 2022

SCOPE OF ENGAGEMENT 

 

I was retained by Defendant Shooters Connection, Inc. to provide expert opinions in the 

case Akai Custom Guns, LLC, et al v. KKM Precision, Inc., et al., Case No. 20-cv61469-RS, United States District Court, Southern District of Florida. I was asked to 

provide an expert opinion on the following subject matters: 

1. The reasonableness of Akai’s alleged repair costs as stated in the PDF Akai # 

538 (“Akai Cost Spreadsheet”). See Exhibit A, attached. 

2. The reasonableness of Akai’s claim for loss of revenue based upon allegedly not 

being able to manufacture guns. 

3. The reasonableness of applying a “tungsten sleeve” via turning down the outside 

dimensions of a barrel on a lathe. 

My findings, conclusions, and opinions as offered herein are based on my review and 

analysis of the documents and information available to me as of the date of this report. 

I reserve the right to supplement and/or amend this report should additional information 

that impacts my opinions become available at a later date.

QUALIFICATIONS

I am the sole owner of Bedell Custom, which is located at 3976 Walden Avenue, 

Lancaster, NY, 14086. Bedell Custom manufacturers and repairs Model 1911, Model 

2011 and other firearms. I have owned and operated Bedell Custom since 1990. I 

have worked as a gunsmith for 30 years in both manufacturing and repairing guns, in 

particular, the Model 1911 and 2011 pistols. I devote approximately 50% of my work to 

repairing guns, the majority of which are Model 1911s and 2011s. In the last 30 years, I 

have replaced hundreds of barrels and have completed hundreds of top ends of Model 

1911 and 2011 pistols. Most of the Model 1911 and 2011 pistols Bedell Custom either 

manufactures or repairs are for competition use, including competitions organized by 

the USPSA. I have been a member of the USPSA since the 1990s, and have regularly 

attended and competed in USPSA, including winning numerous local events.

I am also familiar with the guns made by the Plaintiff, Akai Custom Guns. I have 

repaired several Akai Model 2011 guns. Some of the problems I have repaired on 

Akai’s guns include various reliability issues, including failure to feed and extract and 

poorly fit barrels. 

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 1 of 6
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BACKGROUND OF MODEL 1911 AND MODEL 2011 PISTOLS

The Model 1911 was designed by the gun manufacturer John Browning in 1911. It has 

become the most widely manufactured semi-automatic pistol design in the history of 

firearms. The Model 1911 is the most popular pistol for competition shooting, including 

USPSA competitions. The 2011 was designed by the manufacturer STI, and is very 

similar to the Model 1911. The top ends (which includes the slide, barrel, extractor, and 

firing pin) of the Model 1911 and 2011 are virtually identical.

Competition shooting places a high degree of stress and wear on pistols, including the 

Model 1911 and 2011. The Model 1911 and 2011 were not designed to fire the 

quantity, frequency, and type of rounds used in modern day competition shooting. 

Accordingly, manufacturers are often “pushing the limits” of the Model 1911 and 2011’s 

abilities. This frequently leads to problems such as parts failing and breaking. Barrel

lug failure (including cracking) and slide failure (including cracking) is not uncommon in 

competition shooting using the Model 1911 and 2011.

I attend approximately 20-30 competitions per year in which Model 1911 and 2011 are 

used. I typically receive approximately 10-15 Model 1911 and 2011 pistols every year 

for repair service involving barrels that have exploded at shooting competitions. Barrel 

explosion is generally caused by the user improperly reloading their ammunition, in 

particular, packing too much or not enough gunpowder into the shell. The vast majority 

of competition shooters load their own ammunition.

Akai installs tungsten sleeves on its barrels as part of its manufacturing process in order 

reduce recoil. Installing a sleeve (including a tungsten sleeve) on a moving part, like a 

barrel, is very irregular. In my opinion, installing the sleeve on the barrel may lead to 

problems. The better and universal practice to reduce recoil is adding static weight on a 

static part of the gun, for example, the frame or the grip. 

In addition, it is my understanding that Akai may be installing its tungsten sleeve by 

heating the sleeve and freezing the barrel. In my opinion, this can also lead to 

problems, including compromising the hardness of the barrel. The better manufacturing 

process would be to thread the barrel and the sleeve, and then install the sleeve by 

screwing it onto the barrel. This process only takes approximately 1 hour. 

OPINIONS REGARDING REASONABLENESS OF REPAIR COSTS 

I have reviewed the PDF entitled “Akai # 538” (“Akai Cost Spreadsheet”), attached to 

this report as Exhibit A. Akai appears to be claiming that it spent 20 hours for “barrel 

replacement”, including 8 hours to finish the gun, 8 hours to replace the slide, and 8 

hours for the tungsten sleeve installation, and other labor.

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 2 of 6
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In my opinion, these labor hours and rates are grossly excessive and unreasonable. 

Barrel replacement should only take approximately 4 to 6 labor hours. The process of 

barrel replacement can be described as follows: 

 Fitting the hood, upper lugs, and lower lugs.

 Locking the barrel into the slide. 

 Installing the barrel link to allow for “lock-up”. 

 Fitting the bushing (at the front of the barrel) to the slide. However, because Akai 

uses a “bull barrel” and does not use a bushing, this step is not required in Akai’s 

process. 

 Fitting the compensator to end of barrel. 

 “Reaming the chamber” of the barrel. 

 Polishing the ramp. 

 Installing compensator. 

Akai also indicates in the Akai Cost Spreadsheet that it spent approximately 29 to 37 

hours total for “top end” replacement. In my opinion, this is also a grossly excessive 

and unreasonable amount of time for Akai to perform this work. The top end consists of 

the slide, barrel, compensator, and several other small parts. Replacing the barrel 

(described above) is a major aspect of top end replacement and, again, it should only 

take 4 to 6 hours to replace the barrel. Other than barrel replacement, the only other 

work involved in top end replacement should only take approximately 4 to 6 hours. This 

other top end work includes: 

 Fitting the slide to the frame. I note that Akai describes this as “replacing the 

slide”, and indicates this is an 8-hour process. Again, this is grossly excessive. 

 External machine work to the slide (“slide lightning”). 

 Fitting the barrel. 

 Fitting the extractor. 

 Fitting the firing pin stop. 

As discussed above, Akai also turns down (reducing the outside diameter of the barrel

on a lathe) its barrels on a lathe as part of its barrel installation process in order to fit the 

sleeve. While I do not believe this process is advisable (see above), this turning down 

process on a lathe should only take approximately 20 to 30 minutes. Again, in my

opinion, the better process would be installing the sleeve by threading the sleeve onto 

the barrel, which takes approximately 1 hour.

Akai claims that it spends 8 hours to finish the top end. However, Akai also suggests 

that it pays a vendor $275 to finish its top ends. If Akai pays a vendor $275 to finish the 

top end, then Akai should not be required to perform any finish work. In my experience, 

using the hot salt bluing process, finish work only takes approximately 2-4 hours.

Therefore, in my opinion, Akai spending 8 hours on finish work is unreasonable and

excessive. 

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 3 of 6
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It is also my opinion that Akai’s labor rate of $150 per hour for gunsmithing is excessive

and unreasonable. I charge approximately $75 per hour. In my experience, hourly 

rates for gunsmithing on national basis generally range from $75 to $100 per hour. 

 

OPNIONS REGARDING AKAI’S CLAIM FOR LOSS OF REVENUE

Akai also claims that it lost approximately $364,000 in revenue because of the time it 

took to repair guns. There are 39 guns listed on the spreadsheet. It is my opinion that

Akai’s claim that it lost revenue because it was required to repair these 39 guns is 

unreasonable. 

As to barrel replacement time, as I discuss above, it should take approximately 4-6 

hours to replace a barrel (including compensator). Of the 39 guns on the Akai’s

spreadsheet, 23 involve barrel replacement (some including compensator replacement). 

Assuming it took Akai 6 hours per gun to perform this work, it would take a total of 138 

hours to replace the barrels on all 23 guns. Therefore, it is my opinion that if only one 

gunsmith performed this work at 8 hours per day, it would take approximately 17.25 

days to complete (138/8 = 17.25). 

Regarding top end replacement time, as I discuss above, it should take approximately 

8-12 hours to replace a top end (barrel and other parts). Of the 39 guns on the Akai’s 

spreadsheet, 13 involve top end replacement. Assuming it took Akai 12 hours per gun 

to perform this work, it would take a total of 156 hours (13 guns x 12 hrs/gun) to replace 

the barrels on all 13 guns. Therefore, it is my opinion that if only one gunsmith 

performed this work at 8 hours per day, it would take approximately 19.5 days to 

complete (156/8 = 19.5). 

In addition, in my experience manufacturing competition Model 1911 and 2011 pistols, 

customers will frequently wait 3 to 5 months to receive a new competition pistol after 

placing the order. Customers will also typically wait 1 to 2 months for a pistol to be 

repaired. 

DOCUMENTS / INFORMATION REVIEWED 

1. Akai Cost Spreadsheet

2. Akai website 

3. Interviews with Chuck Bradley 

4. Internet searches of other gunsmith websites

5. Documents filed in this lawsuit 

6. Documents produced by Akai 

COMPENSATION 

I am being compensated at the rate of $200.00 per hour for my services. 

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 4 of 6
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PREVIOUS TESTIMONY PROVIDED

None. 

RELEVANT ARTICLES WRITTEN

None. 

Dated: 5-5-22

Respectfully Submitted, 

/s/ Dan Bedell 

Dan Bedell 

Owner 

Bedell Custom

3976 Walden Avenue

Lancaster, NY 14086

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 5 of 6
Date In Date Out Customer Serial Scope of work Material cost

Finish CostLabor Hours Labor Shipping Total CostsPaid by customerLoss of 

revenue

Loss of profit 

opportunity

Material Cost Labor Hours

01/04/19 4/15/19 Reed TE9087 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Replace barrel $285.00 4

02/18/19 12/10/19 Cao ACGUNS1030 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Compensator $200.00 4

3/5/19 8/5/19 Jimenez ACGUNS1167 Barrel and Comp $150 $275 21 $3,150 $200 $3,775 $0 $7,875 $5,452 Tungsten $100.00 8

02/04/19 3/18/19 Baker ACGUNS1024 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Replace slide $250.00 8

3/13/19 9/24/19 Ruiz ACGUNS1212 Barrel and Comp $650 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529 Finish work 8

3/25/19 4/4/19 Baker AC0022 Barrel replacement $400 20 $3,000 $200 $3,600 $0 $7,500 $5,192 Tunning 4

04/03/19 7/20/19 Guido ACGUNS1180 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Admin 1

05/28/20 2/15/21 Stagnato AC0099 Barrel and Comp $650 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529 Finish $275.00

04/17/19 5/14/19 Draghi ACGUNS1099 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Top end replacement $735.00 29

05/10/19 9/5/19 Koh AC0101 Top end replacement $900 $275 29 $4,350 $200 $5,725 $0 $10,875 $7,529 Top end replacement with tungsten $835.00 37

05/28/19 1/8/20 Stickley AC0081 Top end replacement $900 $275 28 $4,200 $200 $5,575 $0 $10,500 $7,269 Barrel replacement $285.00 9

05/26/19 7/17/19 Brown ACGUNS1142 Barrel and Comp $650 $275 24 $3,600 $200 $4,725 $1,500 $9,000 $6,231 Barrel and compensator $485.00 21

06/12/19 8/6/19 Stagnato AC0098 Barrel and Comp $650 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529 Barrel, comp, tungsten $585.00 29

07/05/19 12/10/19 Mcpherson ACGUNS1165 Top end replacement $900 $275 29 $4,350 $200 $5,725 $1,260 $10,875 $7,529

07/05/19 12/10/19 Mcpherson ACGUNS1166 Top end replacement $900 $275 29 $4,350 $200 $5,725 $1,260 $10,875 $7,529

07/08/19 7/25/19 Soupene ACGUNS1230 Barrel and comp $150 $275 21 $3,150 $200 $3,775 $0 $7,875 $5,452

07/15/19 7/29/19 Draghi AC0088 Top end replacement $900 $275 37 $5,550 $200 $6,925 $0 $13,875 $9,606

07/19/19 12/17/19 Mendoza AC0103 Barrel and comp $650 $275 24 $3,600 $200 $4,725 $0 $9,000 $6,231

9/17/19 10/30/19 Coberly AC0104 Barrel and comp $650 $275 24 $3,600 $200 $4,725 $0 $9,000 $6,231 Labor Charge Per Hour $150.00

09/06/19 1/8/20 Brown ACGUNS1142 Top end replacement $650 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529 Guns per year 120.0

10/16/19 House ACSS1014 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192 52 weeks 2.3

10/16/19 House ACSS1013 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192 Average selling price $6,500.00

10/16/19 House ACGUNS1232 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192 Revenue per day $3,000.00

10/16/19 House ACGUNS1229 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192 Cost per gun $2,000.00

10/16/19 House ACGUNS1233 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192 Profit per day $2,076.92

10/16/19 House ACGUNS1207 Barrel replacement $585 20 $3,000 $0 $3,585 $0 $7,500 $5,192

10/16/19 2/19/20 Cabrera ACGUNS1181 Barrel replacement $650 $275 21 $3,150 $200 $4,275 $0 $7,875 $5,452

10/28/19 11/26/19 Veisz ACGUNS1225 Barrel replacement $650 21 $3,150 $200 $4,000 $0 $7,875 $5,452

11/1/19 5/19/20 Mcpherson ACGUNS1240 Barrel and comp $650 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529 Hours spent on research, diagnosis, testing 100

11/13/19 2/17/20 Massler SAS14332 Barrel and comp $650 $275 21 $3,150 $200 $4,275 $0 $7,875 $5,452 Cost $15,000.00

2/21/20 10/28/20 Thompson ACSS 1015 Barrel and comp $650 $275 37 $5,550 $200 $6,675 $0 $13,875 $9,606 Opportunity $25,961.54

8/17/20 12/9/20 Carter NE 9764 Barrel fat $400 $275 9 $1,350 $200 $2,225 $0 $3,375 $2,337

1/6/20 5/2/20 Carter ACGUNS1035 Tungsten barrel $500 $275 20 $3,000 $200 $3,975 $0 $7,500 $5,192 Total $40,961.54

6/29/20 1/19/21 Wesley ACGUNS1056 Top end replacement $900 $275 37 $5,550 $200 $6,925 $0 $13,875 $9,606

1/7/20 7/14/20 Burbage TE8884 Top end replacement $900 $275 29 $4,350 $200 $5,475 $0 $10,875 $7,529

12/3/21 1/31/22 Tillery ACGUNS1233 Barrel, comp, finish $700 $275 24 $3,600 $200 $4,775 $0 $9,000 $6,231

12/15/20 12/30/20 Baker ACGUNS1223 Tungsten Barrel $500 4 $600 $200 $1,300 $0 $1,500 $1,038

11/15/21 1/30/21 Stein ACGUNS1220 Barrel, comp, finish $700 $275 24 $3,600 $200 $4,775 $0 $9,000 $6,231

10/11/21 12/7/21 Chaffin ACGUNS1100 9 Minor gun $700 $275 29 $4,350 $200 $5,525 $0 $10,875 $7,529 Total Loss: $480,017.69

(Total Profit opportunity + Total Costs)

$26,310 $8,250 972.00 $145,800 $6,600 $186,710 $4,020 $364,500 $252,346

AKAI HOROWITZ #538

Case 0:20-cv-61469-RS Document 207-6 Entered on FLSD Docket 12/05/2023 Page 6 of 6