1

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

____________________________________

)

VANDERSTOK, et al. )

)

Plaintiffs, )

)

v. ) Case No. 4:22-cv-00691

)

GARLAND, et al. )

)

Defendants. )

____________________________________)

CERTIFICATION OF ADMINISTRATIVE RECORD

I, Andrew Lange, pursuant to 28 U.S.C. § 1746, declares and says as follows: I am

currently the Division Chief, Office of Regulatory Affairs, Bureau of Alcohol, Tobacco, 

Firearms and Explosives (ATF). The Office of Regulatory Affairs serves as ATF’s official point 

of contact for all matters relating to the creation and/or changes to ATF’s regulations and rulings, 

and serves as the official liaison to the Department of Justice on all rulemaking projects. The 

information in this certification are based upon my personal knowledge or on information 

provided to me in the course of my official duties.

The materials listed in the index below, to the best of my knowledge, are a true and 

complete copy of the administrative record, filed traditionally because of its size, in the above 

referenced civil action.

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INDEX TO THE ADMINISTRATIVE RECORD

1. Chief Counsel Opinion 21208, dated 3/1/71 

2. Chief Counsel Opinion 22334, dated 1/24/77 

3. ATF Classification Letters

4. Firearms Technology Branch (FTB) Tech Bulletin 14-0, dated 10/28/13 

5. FTB Tech Bulletin 14-0, dated 11/1/13 

6. AR Type Firearm Visual Reference Guide

7. Receiver Blanks Talking Points and Qs & As, dated 4/9/14 

8. Shawn Nelson, “Unfinished Lower Receivers,” Prosecuting Firearms Offenses, Nov. 

2015 

9. United States v. Jimenez, 191 F. Supp. 3d 1038 (N.D. Cal. 2016) 

10. Letter from then Attorney General Loretta Lynch to then Speaker of the House Paul 

Ryan, dated 9/8/16 re: U.S. v. Jimenez with opinion attached. 

11. H.R. Rep. No. 116-88 (May 28, 2019) “Homeland Security Assessment of Terrorists’ 

Use of Ghost Guns Act” 

12. United States v. Rowold, 429 F. Supp. 3d 469 (N.D. Ohio 2019) 

13. Letter from Members of Congress to then ATF Acting Director Regina Lombardo, 

dated 4/23/20 

14. Excerpts from ATF’s website:

“Are there restrictions on who can purchase receiver blanks?”

“Are ‘80%’ or ‘unfinished’ receivers illegal?”

“Does an individual need a license to make a firearm for personal use?”

“What is ATF doing in regard to people making their own firearms?” 

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15. Memo to all United States Attorneys from Executive Office of United States 

Attorneys dated 7/20/20 re: Prosecutions Involving Firearms Frames and Receivers

16. Memo to ATF Acting Director from ATF Chief Counsel dated 12/4/20 re: 

Classification of Polymer80 “Buy Build Shoot” Kits

17. Letter from Senators to President Biden, dated 2/18/21

18. Letter from Senators to President Biden, dated 3/9/21

19. Polymer80 PF940C Pistol Frames, 80% Instructions

20. Letter from Everytown For Gun Safety to Attorney General Merrick Garland, dated 

3/16/21

21. Email dated 3/16/21: Firearm Manufacturers Meeting Request

22. Letter from State Attorneys General to Attorney General Garland, dated 3/22/21

23. Email dated 3/23/21: Firearm Manufacturers Meeting

24. Notes from Firearm Manufacturers Meeting, dated 3/26/21

25. Wall St. Journal: “Ghost-gun concerns prompt feds to meet with firearms makers,” 

dated 3/26/21

26. Application for a Search Warrant, case number 3:20-mj-123-WGC (D. Nev.), filed 

12/9/20

27. ATF Office of Strategic Intelligence and Information (OSII), Criminal Intelligence 

Division, “Self-Made Unserialized Firearm Developments,” dated 9/24/19

28. Homeland Security Intelligence Assessment, dated 4/22/19

29. Joint Intelligence Bulletin, “Ghost Guns Challenge Law Enforcement,” dated 1/11/19

30. ATF, OSII, “Increased Possession of Privately Made Firearms (PMFs) by Prohibited 

Persons,” dated 12/15/20

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31. Baltimore Sun: “Baltimore police report a 400% increase in untraceable ‘ghost guns,’ 

as legislators consider action,” dated 2/18/21

32. Email dated 3/30/17 FW: Firearms Ruling

33. Email dated 10/1/20 RE: seeing the various types of silence[r]s with attachment: 

General Silencer Information

34. Email 11/30/20 RE: percentage of electronic storage of Form 4473

35. Email 12/15/20 RE: markings on silencers, existing ones

36. Email 12/15/20 RE: Form 4473 storage

37. Email 12/15/20 RE: new Definition of Receiver: Number historically produced

38. Email 12/22/20 RE: number of filing cabinets

39. Email 12/30/20 RE: how many boxes for out of business records?

40. Email 1/11/21 RE: Companies affected by New Definition of Receiver

41. Email 2/23/21 RE: Definition of Frame or Receiver

42. Email 3/1/21 RE: Silencer costs

43. Email 3/2/21 RE: 20 Year + firearms traces

44. Email 3/2/21 RE: FW: type 7 FFL with SOT

45. Email 3/3/21 electronic storage of 4473’s

46. Explanations of data – PMFs or Ghost Guns dated 3/4/21

47. Email 3/9/21 FW: New Definition of Receiver: FFLs that did not receive a 

determination with photos

48. Email 3/16/21 RE: Number of companies that sell silencers

49. Email 3/17/21 RE: New Def Rec: silencers

50. Email 3/23/21 RE: Individual Purchases of Silencers

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51. Email 3/24/21 Business Use of Serial Numbers

52. Email 4/1/21 FW: Shipping records to ATF

53. Email 4/2/21 RE: Shipping records to ATF

54. Fact Sheet: Biden-Harris Administration Announces Initial Actions to Address the 

Gun Violence Public Health Epidemic, dated 4/7/21

55. Email 4/20/21 FW: PMFs 3D printed in Spain

56. Email 4/29/21 FW: PMFs successfully traced with attachments: Completed 

Personally Made Firearms Traces, Calendar Year 2016-2020 and PMF Successful 

Traces

57. Email 4/30/21 RE: 20 year + firearms traces with attachment: Trace Completion 

Codes and 20 Year Traces

58. ATF, OSII, Criminal Intelligence Division: Completed Personally Made Firearms 

Traces, Calendar Year 2016 – 2020

59. Science News: “3-D printed ‘ghost guns’ pose new challenges for crime scene 

investigators,” dated 9/24/19

60. Los Angeles Times: “5 dead in Santa Monica rampage, gunman acted alone, police 

say,” dated 6/7/13

61. The Washington Post: “District seeks to ban ‘ghost gun’ kits as seizures of 

homemade weapons soar”

62. Los Angeles Times: “LA gangs stockpile untraceable ‘ghost guns’ that members 

make themselves,” dated 7/6/18

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63. New York Attorney General’s Press Release: “AG Schneiderman Announces 11 Year 

Jail Sentence of Defendant Convicted for Illegally Trafficking Untraceable ‘Ghost 

Guns,’” dated 4/28/16.

64. San Francisco Chronicle: “’Ghost guns’ present a challenge to public safety,” dated 

3/10/20

65. Time: “The Saugus High School Shooter Used an Illegal ‘Ghost Gun,’” dated 

11/23/19

66. The Trace: “ATF is Shutting Down Businesses It Says Are Hawking Silencers 

Disguised as Cleaning Tools,” dated 5/12/17

67. Center for American Progress: “The Gun Industry in America,” dated 8/6/20

68. ATF Report of Active Firearms Licenses, dated 1/11/21

69. New Definition of Firearm Frame or Receiver summary

70. Small Arms Survey: “Issue Brief,” No. 17, March 2016

71. Jurgen Brauer, “The U.S. Firearms Industry: Production and Supply,” 2013

72. Small Arms Survey: Annual Report 2018

73. Matt Schroeder, Small Arms Survey, “On the Record: Illicit Weapons in the United 

States,” 2014

74. OneStop Reports

75. AP News: “Design of AR-15 could derail charges tied to popular rifle,” dated 1/13/20

76. U.S. Bureau of Labor Statistics (BLS), Occupational Employment and Wages, May 

2019: Mechanical Engineers

77. Pages from websites:

80% Lowers

JSD Supply

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80% Arms

MDX Arms

Ghost Guns 

Defense Distributed

American Weapons Components 

80-Lower.com

78. BLS Occupational Employment and Wages, May 2019: Forging Machine Setters, 

Operators, and Tenders, Metal and Plastic

79. BLS Occupational Employment and Wages, May 2019: Cutting, Punching and Press 

Machine Setters, Operators and Tenders, Metal and Plastic

80. Amazon pages re: steel metal stamps

81. Google shopping pages re: stamping tools 

82. BLS Occupational Employment and Wages, May 2019: Cashiers 

83. Pages from websites:

VelocityWorks 

Las Vegas Laser Engraving

Engrave It Houston 

Tar Heel State Firearms

84. Regulatory Analysis Research Tables

85. Definition of Frame or Receiver and Identification of Firearms, Preliminary 

Regulatory Analysis and Initial Regulatory Flexibility Analysis, April 2021 

86. Notice of Proposed Rulemaking: Definition of “Frame or Receiver” and 

Identification of Firearms, dated 5/21/21 

87. Link to comments: www.regulations.gov/docket/ATF-2021-0001/comments

88. Comment matrix

89. Form Letters: full comment language

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90. Powerpoint: “ATF’s Notice of Proposed Rulemaking (NPRM) Clarifying ‘Frame or 

Receiver’ Definition”

91. Comments spreadsheets

92. Email 7/23/21 FW: refinishing Engravings on firearms

93. Email 9/9/21 RE: Economic comments: Definition of Receiver

94. Email 9/10/21 RE: gunsmithing expertise requested with FFL licensing requirements

95. Email 10/20/21 RE: recent experience as a gunsmith requested

96. Email 10/20/21 RE: gunsmiths engraving PMFs

97. Email 12/21/21 FW: PMF training – case study

98. Email 1/3/22 RE: firearms traces older than 20 years linked to successful prosecution 

cases

99. Summary of Successful Prosecution Cases

100. Email 1/4/22 RE: New Def Rec. Serializing PMFs for type 3 Collectors

101. Email 1/6/22 FW: response

102. Excerpt from GAO: Firearms Data: ATF Did Not Always Comply With the 

Appropriations Act Restriction and Should Better Adhere to Its Policies, June 2016

103. Email 1/10/22 RE: Age of Firearms from Traces older than 20 years with attachment: 

Firearm Age Breakdown 21-70 years

104. Email 1/10/22 Fwd: [Redacted] Data

105. National Tracing Center: Unsuccessful Crime Gun Traces due to destruction of 20-

year records, January 2022

106. Email 1/12/22 RE: Safety Equipment at an FFL

107. Email 1/19/22 FW: Response with attachment: Traces__C3__and [redacted]

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108. Email 1/21/22 RE: Update to Table with attachment: 20+ Year Firearms Tracing Stats

109. ATF, OSII, Criminal Intelligence Division: Suspected Privately Made Firearms 

(PMF) Traces, Calendar Years 2016 through 2021

110. Email 1/25/22 RE: update

111. Email 1/25/22 20+ Year Active Records

112. Email 1/25/22 RE: Follow-up request from ORA

113. Email 1/25/22 RE: Jeff’s experience

114. Email 1/26/22 RE: NTC Analysis of 20 year record retention

115. Email 1/26/22 Update to Table with attachment: 20+ Year Firearms Tracing Stats

116. Email 1/27/22 Electronic A&D Costs with attachment: Electronic A&D Costs

117. Email 1/27/22 RE: Type 7 FFL Records Retention Information Request

118. Email 1/27/22 RE: Electronic A&D Costs

119. Email 1/27/22 RE: total cases of Homicide and Violent Crime with attachment: 

Explanations of data for PMF Analysis Final NPRM

120. Email 1/27/22 RE: total cases of Homicide and Violent Crime with attachment; 

Explanations of data for PMF Analysis – Felon in Possession

121. Chart and graph: Total Suspected PMFs by Calendar Year

122. Email 1/27/22 RE: Successful Prosecution Cases Time to Crime 20+ Years

123. Email 1/28/22 RE: PMF Overnight Repairs/Customization

124. Email 2/2/22 RE: NFAD Totals

125. Email 2/8/22 RE: Electronic Storage of Form 4473

126. FBI CJIS/NICS Comments to draft Final Rule and ATF Response

127. Excerpt from Science and Engineering of Small Arms

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128. Letter from Senators to CEO of YouTube, Inc., dated 2/14/22

129. Email 1/26/22 FW: C3 traces with attachment: C3 Traces 2010+

130. Trace Details PMF with Purchaser Trace Data 1/21/22

131. BLS News Release: Employment Cost Index June 2021

132. BLS News Release: Employment Cost Index March 2021

133. BLS News Release: Employment Cost Index September 2021

134. Australian Institute of Criminology, “Cost benefit analysis and its application to 

crime prevention and criminal justice research,” 2011

135. House of Representatives Joint Economic Committee Testimony: Cost of Firearm 

Injuries and Deaths, dated 9/18/19

136. RAND: “Effects of Low-Quality Handgun Bans on Violent Crime,” 2020

137. RAND: “Effects of Licensing and Permitting Requirements on Violent Crime,” April 

2020

138. Criminology and Public Policy: “Evidence concerning the regulation of firearms 

design, sale, and carrying on fatal mass shootings in the United States,” 2020

139. RAND: “How Gun Policies Affect Violent Crime,” updated April 2020

140. Criminology and Public Policy: “Evidence concerning the regulation of firearms 

design, sale, and carrying on fatal mass shootings in the United States,” 2020 

(duplicate)

141. 81 Fed. Reg. 2658, “Machineguns, Destructive Devices and Certain Other Firearms, 

Background Checks for Responsible Persons of a Trust or Legal Entity with Respect 

to Making or Transferring a Firearm,” 1/15/16

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142. Small Arms Survey: “Taking Stock of action on the illicit small arms trade: Measures 

to address the diversion of small arms,” dated 7/17/20

143. Small Arms Survey: “Implications for the International Tracing Instrument of 

marking and tracing polymer and modular weapons,” dated 7/7/20

144. Small Arms Survey: “Craft weapons,” dated 6/19/20

145. Small Arms Survey: “National Action Plan as a strategic tool for weapons and 

ammunition management/small arms control,” dated 6/22/20

146. Small Arms Survey: “The role of regional organizations,” dated 6/23/20

147. Small Arms Survey, Issue Brief, No. 17, March 2016

148. Jurgen Brauer, “The U.S. Firearms Industry: Production and Supply,” 2013

149. Small Arms Survey Annual Report 2018

150. Matt Schroeder, Small Arms Survey, “On the Record: Illicit Weapons in the United 

States,” 2014

151. Washington State Institute for Public Policy: “What Works and What Does Not?” 

February 2018

152. OneStop Reports

153. Final costs table

154. Web pages from:

SMF Tactical

Modulus Arms

80% Lowers

80-Lowers.com

AK-Builder.com

Get Lowers.com

Omega Tactical Distribution

1776SupplyCo.com

Ormond Arms

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American Made Tactical

Righttobear.com 

Broken Arms 

5D Tactical

Venom Defense and Design

80% Arms

American Weapons Components 

1911 Builders 

Defense Distributed

James Madison Tactical

Durkin Tactical

The Flat Spot 

TR-Enabling 

Wardogz 

BossLaswer Metal Cutting Machines

Daikin 10 Ton Air Conditioner Air Handler 

Las Vegas Laser Engraving

Vulture Equipment Works 

Call to Arms Gun Works 

Tar Heel State Firearms

Grainger Single Piece Air Handler

Toolots: Marking machines 

Easy Bound Book Firearms Software

Express Log Book 

EZ Arms Keeper

Orchard FFL Bound Book Software 

Gun Store Master

Logbooks for guns 

155. List of barcode scanners 

156. List of recordkeeping software 

157. Final Economic Spreadsheets 

158. “Definition of ‘Frame or Receiver’ and Identification of Firearms,” Regulatory 

Impact Analysis and Final Regulatory Flexibility Analysis, April 2022 

159. Transcript of Motion Hearing on 9/26/19, United States v. Rowold, 3:18-cr-387 (N.D. 

Ohio) 

160. Chief Counsel Opinion, dated 3/1/71 

161. Chief Counsel Opinion, dated 1/24/77 

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162. Military.com: “Army Picks Sig Sauer’s P320 Handgun to Replace M9 Service 

Pistol,” dated 1/19/17

163. TaskandPurpose.com: “Every U.S. military branch is about to get its hands on the 

Army’s new sidearm of choice,” dated 11/18/20

164. AP News: “Design of AR-15 could derail charges tied to popular rifle,” dated 1/13/20

165. Washington Post: “Magruder student bought ‘ghost gun’ components online before 

wounding classmate, prosecutor says,” dated 1/24/22

166. NBCPhiladelphia.com: “3 Pipes Turned into a Shotgun: Nearly 1-in-10 Guns Seized 

in Philly Are Homemade,” dated 10/7/21

167. Rockefeller Institute of Government: “Ghost Guns: A Haunting New Reality,” April 

2021

168. Los Angeles Times: “LAPD declares ‘ghost guns’ an ‘epidemic’ citing 400% 

increase in seizures,” dated 10/15/21

169. The New York Times: “’Ghost Guns’: Firearm Kits Bought Online Fuel Epidemic of 

Violence,” dated 11/14/21

170. Chicago Tribune: “We’re seeing an explosion,” dated 10/14/21

171. ClickOrlando.com: “Untraceable ‘Ghost Guns’ sold across Central Florida,” dated 

11/5/16

172. DOJ Press Release: Barnstable Man Charged with Firearm Trafficking, 6/22/21

173. DOJ Press Release: Big Island man arrested on methamphetamine and firearm 

charges, 5/18/21

174. DOJ Press Release: Bronx Man Who Possessed Five “Ghost Guns” Charged With 

Possessing A Firearm And Ammunition, 10/5/21

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175. DOJ Press Release: Brooklyn Felon Sentenced to 48 Months’ Imprisonment for 

Possessing Arsenal of Weapons Including “Ghost Guns,” 10/12/21 

176. DOJ Press Release: Buffalo Man Arrested, Charged With Manufacturing Ghost Guns,

8/20/21

177. DOJ Press Release: Burlington Man Pleads Guilty to Ammunition Charge, 12/12/18

178. DOJ Press Release: Burlington Man Sentenced For Ammunition Charge, 3/19/19

179. DOJ Press Release: Cedar Rapids Man Pleads Guilty to Drug Trafficking and 

Possessing Machineguns and a Pipe Bomb, 1/21/20

180. DOJ Press Release: Colchester Man Sentenced to 34 Months in Federal Prison for 

Illegally Possessing Machinegun, 11/12/21

181. DOJ Press Release: Connecticut Man Sentenced for Firearm Trafficking, 9/16/21

182. DOJ Press Release: Convicted Felon Sentenced for Narcotics Trafficking and 

Manufacturing “Ghost Guns,” 9/24/21

183. DOJ Press Release: Convicted Gun Trafficker Pleads Guilty to Firearms Charges, 

6/22/21

184. DOJ Press Release: Dark Web Gun Trafficker from Nevada County Pleads Guilty to 

Unlawful Dealing in Firearms, 6/22/18

185. DOJ Press Release: D.C. Felon Sentenced to 30 Months in Federal Prison for Illegal 

Possession of a .40 Caliber “Ghost Gun” Firearm and 10 Rounds of Ammunition,

9/24/21

186. DOJ Press Release: Denver Gang Member Sentenced To Over 15 Years In Federal 

Prison For Making And Selling Dozens Of High Powered Guns, Including Machine 

Guns And Silencers, 11/22/19

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187. DOJ Press Release: District Man Sentenced to 10 1⁄2 Years in Prison for Armed 

Robbery and Earlier Shooting, 10/13/21

188. DOJ Press Release: Federal Drug and Gun Charges Brought Against Fresno Man 

Accused of Dealing Fentanyl, 7/15/21

189. DOJ Press Release: Felon Pleads Guilty to Possession of Ghost Guns and Conspiracy 

to Commit Wire Fraud, 6/28/21

190. DOJ Press Release: Fishers Residents Indicted on Terrorism and Firearms charges, 

7/12/19

191. DOJ Press Release: Fresno Felon Indicted for Possession of Ammunition, 10/7/21

192. DOJ Press Release: Fresno Gang Member Faces Federal Firearms Charge, 6/3/21

193. DOJ Press Release: Fresno Men Indicted for Being Previously Convicted of Violent 

Crimes in Possession of Firearm and Ammunition, 9/16/21

194. DOJ Press Release: Gang Member Sentenced to More Than 7 Years in Prison for 

Gun and Drug Offenses, 2/17/21

195. Courant.com: “Gang Task Force accused two East Hartford men of using 3D printers 

to manufacture and sell hard-to-track ‘ghost guns,’” dated 1/7/22

196. DOJ Press Release: Hartford Man Charged with Illegally Possessing Firearm and 

Ammunition, 7/23/21

197. DOJ Press Release: Indiana Residents Indicted on Terrorism and Firearms Charges,

7/11/19

198. DOJ Press Release: Indictment Charges 15 Members of a Los Angeles Drug 

Trafficking Ring that Distributed Heroin, Methamphetamine and Cocaine, 2/12/20

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199. DOJ Press Release: Laplace Man Pleads Guilty to Being Felon in Possession of 

Ammunition, 6/25/21

200. DOJ Press Release: Las Vegas Man Charged For Illegally Engaging In The Business 

Of Manufacturing Machine Guns Without A License, 9/4/19

201. DOJ Press Release: Lawrence Man Arrested on Firearms and Narcotics Charges, 

11/4/21

202. DOJ Press Release: Man Sentenced for Attempting to Board International Flight with 

a Loaded Firearm, 3/12/21

203. DOJ Press Release: Mexican National Charged with Possessing Firearms, 

Methamphetamine in Checked Luggage at MSP Airport, 11/2/21

204. DOJ Press Release: Montgomery County Man Sentenced to 30 Months for Unlawfully 

Selling “Ghost Guns,” 9/2/21

205. DOJ Press Release: New Haven Gang Member Charged with Federal Firearm and 

Narcotics Offenses, 11/17/21

206. DOJ Press Release: New Mexico Man Who Sold ‘Ghost Guns’ Indicted, 9/8/21

207. DOJ Press Release: Ocean County Man Charged with Illegally Possessing Loaded 

Semi-Automatic Rifle, 11/16/21

208. DOJ Press Release: Outlaws Motorcycle Club Regional President Pleads Guilty to 

Firearms Charges, 7/15/20

209. DOJ Press Release: Philadelphia Man Arrested on Murder-for-Hire Charges: 

Attempt Homicide in Southwest Philadelphia Thwarted, 7/26/21

210. DOJ Press Release: Raleigh Felon Sentenced After Pulling a Firearm on Officers 

During a Drug Investigation, 8/17/21

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211. DOJ Press Release: Rensselaer County Felon Sentenced to 30 Months on Firearms 

Convictions, 8/10/21

212. DOJ Press Release: Second Defendant Charged with Murder in New Indictment in 

Case of Man Found Dead in Pacific Ocean after Being Shot on a Boat, 6/25/20

213. DOJ Press Release: Septuagenarian charged with manufacturing “ghost guns”

6/15/21 

214. DOJ Press Release: Seven Defendants Arrested and Charged in Conspiracy to 

Possess and Carry Firearms in Furtherance of Drug Trafficking, 9/3/20

215. DOJ Press Release: Sun Valley Man Indicted on Federal Narcotics Charges and 

Weapons Offenses, including Possession of Ghost Gun and Grenade Launcher, 

7/23/20

216. DOJ Press Release: Syracuse Man Pleads Guilty to Brokering Illegal Gun Sales, 

12/9/20

217. DOJ Press Release: Syracuse Man Pleads Guilty to Unlawfully Possessing and 

Selling Firearms and Ammunition, 10/15/21

218. DOJ Press Release: Syracuse Man Sentenced to Seven Years in Federal Prison for 

Brokering Illegal Gun Sales, 7/8/21

219. DOJ Press Release: Takedown Completes Arrests of 15 Alleged Drug Traffickers in 

Syracuse Area, 9/17/20 

220. DOJ Press Release: Tattoo Shop Owner Sentenced to Prison for Possessing 

Unlicensed Firearms at his Business, 10/28/21

221. DOJ Press Release: Temple Hills Man Sentenced To Three And A Half Years In 

Federal Prison For Trafficking Of Ghost Guns, 6/4/21

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222. DOJ Press Release: Three East Bay Men Charged With Conspiracy To Traffic 

Firearms, 8/16/21

223. DOJ Press Release: Three Members of Gardena Street Gang Charged in Federal 

Racketeering Case Alleging Murder of Man Outside His Home, 12/2/20

224. DOJ Press Release: Three South Lake Tahoe Residents Charged with Drug 

Trafficking and Texas Man Charged with Trafficking Firearms, 8/23/21

225. DOJ Press Release: Two Defendants Indicted For Oahu Game Room Robbery, Drug 

Trafficking, and "Ghost Gun" Possession, 9/17/21

226. DOJ Press Release: Two District Men Indicted on Federal Charges Involving Illegal 

Possession and Sale of Firearms, 9/29/21

227. DOJ Press Release: Two Men Indicted for Firearms Trafficking, 10/28/21

228. DOJ Press Release: Two Queens Men Charged After Buying Three Illegally Defaced 

Firearms and Two Assault Rifles, 5/13/20

229. DOJ Press Release: Two Stockton Residents Sentenced for Firearms Offenses, 

11/21/19

230. DOJ Press Release: Vacaville Man Sentenced to over 4 Years in Prison for 

Unlawfully Possessing Ammunition as a Felon, 5/4/21

231. DOJ Press Release: Vineland Boys Gang Member Sentenced to 31 Years in Federal 

Prison for Racketeering Conspiracy, Attempted Murder of Rival Gangsters, 7/22/21

232. CNN: “A Rhode Island man was arrested for allegedly selling ‘ghost guns’ and 

trafficking the firearms to the Dominican Republic,” dated 1/9/22

233. Armament Research Services (ARES): “Firearms using 3-D printed components 

seized in Sweden,” 5/19/17

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234. Anu.edu: “Glock ghost guns up for grabs on the dark web,” 3/23/21

235. ARES: “Multiple 3D-printed Firearms Seized in Sydney, Australia,” dated 8/11/20

236. BBCNews: “Spain dismantles workshop making 3D-printed weapons,” 4/19/21

237. The Independent: “Use of 3D printed guns in German synagogue shooting must act as 

warning to security services, experts say,” October 2019

238. Homeland Security Intelligence Assessment, dated 4/22/19

239. H.R. Report 116-88, “Homeland Security Assessment of Terrorists’ Use of Ghost 

Guns Act,” dated 5/28/19

240. Joint Intelligence Bulletin, “Ghost Guns Challenge Law Enforcement,” dated 1/11/19

241. 3dprintingmedia.network: “Oceanian media report seizures of 3D printed guns, 

submachine guns,” dated 6/22/21

242. ABC7 Chicago: “Al Qaeda launches 1st public campaign in 4 years to encourage lone 

wolf terrorist attacks,” dated 7/29/21

243. Smh.com: “Alleged right-wing extremist charged over blueprint to 3D-print a gun,” 

dated 9/13/21

244. Tucson Sentinel: “CBP: 3-D printed full-auto rifle seized at Lukeville crossing”

245. International Centre for Counter-Terrorism: “CTRL, HATE, PRINT: Terrorists and 

the Appeal of 3D-Printed Weapons,” dated 7/13/21

246. DOJ Press Release: Dark Web Gun Trafficker from Nevada County Pleads Guilty to 

Unlawful Dealing in Firearms, dated 6/22/18

247. DOJ Press Release: Fishers Residents Indicted on Terrorism and Firearms charges, 

dated 7/12/19

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248. DOJ Press Release: Grass Valley Man Sentenced to 5 Years in Prison for Unlawfully 

Manufacturing Ghost Guns and Selling them on Dark Web, dated 9/21/18

249. DOJ Press Release: Indiana Residents Indicted on Terrorism and Firearms Charges, 

dated 7/11/19

250. DOJ Press Release: Man Sentenced for Attempting to Board International Flight with 

a Loaded Firearm, dated 3/12/21

251. DOJ Press Release: Mexican National Charged with Possessing Firearms, 

Methamphetamine in Checked Luggage at MSP Airport, dated 11/2/21

252. The Independent: Police issue warning over terrorist use of 3D-printed guns as UK 

neo-Nazi jailed,” dated 6/14/21

253. Nextgov.com: “TSA Confiscated 3D Printed Gun at Raleigh-Durham International 

Airport”

254. Time: “The TSA Has Found 3D-Printed Guns at Airport Checkpoints 4 Times Since 

2016,” dated 8/2/18

255. Al Jazeera Weapons News: “What’s behind far-right trend of using 3D tech to make 

guns?” dated 7/31/21

256. Wjla.com: “Bill to ban ghost guns passes in Maryland House, heads to Gov. Hogan’s 

desk,” dated 3/29/22

257. Press Release – Montgomery County Council: Counsel unanimously approves Ghost 

Guns bill, restricting the sale of transfer of ghost guns to minors, dated 4/6/21

258. Denver Gazette: “Denver outlaws owning manufacturing ‘ghost guns’ in the city,” 

dated 1/3/22

259. Los Angeles Times: “L.A. City Council votes to ban ‘ghost guns,’” dated 12/1/21

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260. CBS8.com: “Mayor Gloria signs ban on ghost guns in San Diego,” dated 1/3/22

261. Mercurynews.com: “Oakland joins growing list of California cities to ban ghost 

guns,” dated 1/18/22

262. Reason.com: “Philadelphia Becomes First City to Ban 3D-Printed Gun 

Manufacturing,” 11/22/13

263. ATF Fact Sheet – eTrace: Internet Based Firearms Tracing and Analysis, September 

2021

264. Explanations of data: Privately Made Firearms (PMFs) or Ghost Guns, dated 1/21/22

265. ATF, OSII, Criminal Intelligence Division: Suspected Privately Made Firearm (PMF) 

Traces, Calendar Years 2016 through 2021

266. Excerpt from “Following the Gun: Enforcing Federal Laws Against Firearms 

Traffickers,” June 2000

267. Inland Empire News: “Deputy recovers ‘ghost gun’ from convicted felon during 

traffic stop,” dated 8/10/21

268. AP News: “Felon on supervision accused of having ‘ghost gun’ arsenal”

269. SPD Blotter: “Georgetown Arrest of Felon Leads to Recovery of Ghost Gun,” dated 

11/8/21

270. LehighValleyLive.com: “Lehigh Valley felon was using 3D printer to make ‘ghost 

guns’ at home, Pa. attorney general says,” dated 1/29/21

271. NBCPalmSprings.com: “Parolee Arrested With AR-15 Ghost Gunk, Fake Law 

Enforcement Badge,” dated 8/13/21

272. Excerpt from The National Firearms Act Handbook, April 2009

273. FFL Newsletter May 2012

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274. FFL Newsletter September 2011

275. ATF Ruling 2016-1

276. ATF Ruling 2016-2

277. Hawkridgesys.com: “How to Insert Internal Components with Markforged Composite 

3D Printing”

278. 3dprintingindustry.com: “LehVoss Group Leads Innovate UK Project for 

Overprinting High-Performance Polymers,” 8/25/21

279. Markforged.com: “MMF #5: A Guide to Embedding Components in 3D Printed 

Parts”

280. Excerpt from US Attorney’s Manual, Section 9-27.260: Initiating and Declining 

Charges—Impermissible Considerations

281. ATF memo regarding M16 serial numbers, dated 2/2/73

282. Letter from Acting Chief, Firearms Technology Industry Services Branch, to Mark 

Barnes, Esq., dated 3/20/15

283. NBC News: “Senators call on YouTube to crack down on ‘ghost gun’ videos,” dated 

2/15/22

284. NBC News: “YouTube banned ‘ghost gun’ videos. They’re still up.” Dated 1/24/22

285. Pennlive.com: “’Ghost gun’ used in shooting that killed two outside Snyder County 

restaurant,” dated 7/14/20

286. CNN: “The gunman in the Saugus High School shooting used a ‘ghost gun,’ Sheriff 

says,” 11/21/19

287. DOJ Press Release: Bridgeport Felon Sentenced to More Than 5 Years in Federal 

Prison for Possessing Firearms, 1/7/21

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288. TimesofSanDiego.com: “Convicted Felon Nabbed in Lakeside with Meth, Ghost 

Guns and Burglary Tools,” dated 1/29/22

289. KymKemp.com: “Felon Found With ‘Ghost Gun’ Arrested, says HCSO,” dated 

11/29/21

290. SPD Blotter: “Georgetown Arrest of Felon Leads to Recovery of Ghost Gun,” dated 

11/8/21

291. KIRO 7 News: “’Ghost guns’: Loophole allows felons to legally buy gun parts 

online,” dated 2/22/18

292. LehighValleyLive.com: “How the felon killed at Walmart got his handgun, DA says,” 

dated 5/9/18

293. LehighValleyLive.com: “Lehigh Valley felon was using 3D printer to make ‘ghost 

guns’ at home, Pa. attorney general says,” dated 1/29/21

294. Boston.com: “Winthrop man had homemade ‘ghost’ guns and 3,000 rounds of 

ammunition, prosecutors say,” dated 8/5/20

295. ATF Ruling 2009-1

296. Congressional Research Service, “Statutory Federal Gun Registry Prohibitions and 

ATF Record Retention Requirements,” dated 3/4/22

297. Excerpt from Science and Engineering of Small Arms, 2021

298. Excerpt from Sporting Arms and Ammunition Manufacturers’ Institute Glossary

299. ATF Ruling 2003-1

300. ATF Ruling 2003-2

301. ATF Ruling 2003-3

302. ATF Ruling 2003-4

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303. ATF: How to Properly Destroy Firearms, dated 8/14/19

304. Official Journal of the European Union, Commission Implementing Directive 

2019/68 of 1/16/19 establishing technical specifications for the marking of firearms 

and their essential components

305. ATF Ruling 77-1

306. ATF Website Q&A: “Does a gunsmith need to enter every firearm received for 

adjustment or repair into an acquisition and disposition (A&D) record?” Dated 

7/13/20

307. Memo to Heads of All Department Components from the Attorney General re: 

Issuance and Use of Guidance Documents by the Department of Justice, dated 7/1/21

308. USPS.com: Publication 52 – Hazardous, Restricted and Perishable Mail, section 43: 

Firearms definitions

309. TTB.Gov Q&As: Firearms/Ammunition Excise Tax, Manufacturers and Producers

310. Revenue Ruling 61-189

311. Office of Management and Budget Circular A-4, dated 9/17/03, to the Heads of 

Executive Agencies and Establishments re: Regulatory Analysis

312. ATF Website: Rulings, dated 10/20/21

313. Office of Justice Programs, Bureau of Justice Statistics: “Source and Use of Firearms 

Involved in Crimes: Survey of Prison Inmates, 2016,” January 2019

314. ATF: “Highlights of Definition of ‘Frame or Receiver’ and Identification of Firearms 

Final Rule

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315. Memo from then Acting ATF Director Marvin Richardson to Attorney General 

Garland re: Final Rule concerning the definition of ‘frame or receiver’ and 

identification of firearms

316. 87 Fed. Reg. 24652 (4/26/22), “Definition of ‘Frame or Receiver’ and Identification 

of Firearms

I certify under penalty of perjury that the foregoing is true and correct.

Executed on this 24th day of October, 2022.

______________________________

Andrew Lange

Division Chief

Office of Regulatory Affairs

Bureau of Alcohol, Tobacco, Firearms and

Explosives

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