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There was actually a very wacky attempted work around called the "sputter gun". It was basically a STEN gun, sans trigger, that the shooter would load up, drop the bolt, and away it went. IIRC, once started, there was no way to stop it until all the cartridges in the magazine were discharged. Unsurprisingly, BATFE still classified it as a machine-gun and that was the end of that.I am pretty sure they would consider the act of slamming in the mag the "trigger" in that case. You actuated the gun by putting in the mag, ergo that is the trigger.