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And to further compound things, As I posted upthread, all other Semi Autos have the LOWER as the Registered part NOT the Upper, so I think they screwed the pooch when they made the AR the same way, not realizing the work arounds of flip flopping uppers, which the others can do, but the AR is stupid simple, so Yea,.......................The Cali gun control case that went quietly was precisely because the Federal Gun Control Act specifically has this "firearm frame or receiver" as "that part of a firearm which provides housing for the hammer, bolt or breechblock, and firing mechanism, and which is usually threaded at its forward portion to receive the barrel." So it would seem that from the beginning ; the ATF have been wrong about what serialized part is needed and is why the proposed addendum includes the upper receiver.
Edit. Because of that definition, the lawyers for the Cali case dropped it, so that they wouldn't admit that practically no AR15 on the market met the definition of "frame or receiver" and thus would have meant that they were all legal as "unregistered" firearm parts