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The argument was that the legislative department has the power to control these via laws, not the ATF via "rule earning", and Because the NFA was laws enacted by congress it was the relevant regulation listed here. And as it defines semi auto by functionality from the trigger, that is https://frttriggerforsale80123.plpwiki.com/7038628/rare_breed_frt_trigger_no_further_a_mystery

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