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The problem with that large of a number is that it far outnumbers the number of "modern sporting rifles " (both AR and AK types) estimated to have been manufactured and imported into the US from 1990-2020 according to NSSF...They also want to think there's only 3-7 millions braces in circulation, when it's actually 10-40 million.
Commonly Owned: NSSF Announces Over 24 Million MSRs in Circulation
NSSF updated the industry estimate of Modern Sporting Rifles (MSRs) in circulation in the United States to 24,446,000 since 1990.
www.nssf.org
So, saying there's up to 40 million "pistol braces" would seem to indicate a far larger number of AR and AK patterned pistols than rifles?