FEB 2 3 1999            903050:EMO


Mr. Curtis Debord
American Arms Delta
1469 Greg Street
Sparks, Nevada 89431

Dear Mr. Debord:

This refers to the semiautomatic firearm that was
received in this office on February 1, 1999, for classification.,

Examination of the submitted sample, serial number
AM0001, indicates that it is a semiautomatic
firearm, in caliber .303 British, that is based on the design of the Vickers machinegun. The receiver has
been originally designed and manufactured to permit
only semiautomatic fire.

The right side plate has been manufactured with two
integral steel rails that protrude from the inside of
the plate, into the receiver cavity. These rails
begin at the rear of the trunion and extend
approximately 7 7/8 inches toward the rear of the side
plate. The upper rail is approximately 7/16 inch in
height, and the lower rail is approximately 1/4 inch
in height. The rails protrude approximately .069
inches in to the receiver cavity. The purpose of the
rails is to prevent the installation of standard
Vickers machinegun recoil plates. The opening for
the bolt block in the recoil plates have also been
modified to prevent the installation of a standard
Vickers machinegun bolt block.

A steel plate approximately 1 21/32 inches in length
and approximately 3/16 inch in thickness is pinned and
welded to each side plate in the area of the top cover
hinge. This plate contains a sliding firing linkage.
This plate prevents a standard Vickers machinegun bolt
block assembly from being installed into the weapon





Mr. Curtis Debord


A Vickers machinegun bolt block assembly has been
redesigned by machining away an area approximately
1 5/8 inches in length by 3/8 inch deep from the front
upper area of the bolt block. The bolt slide face has
also been reduced in height by approximately 1/4 inch.
A pivoting and sliding sear plate has been attached to
the sear and is located in the described machined away
area of the bolt block. This sear plate is designed
to slide under the plate welded between the side
plates and tilt upwards to engage the sear linkage.
The lugs on the bottom of the bolt block have been
reshaped to make them compatible with the altered
recoil plates.

The redesigned mechanism incorporates a positive
disconnector that prevents the weapon from firing more
than one shot for each function of the trigger.
Additionally, standard Vickers machinegun, firing
pins, sears and firing pin springs are not compatible
with the redesigned weapon.

You also indicated that the side plates will be welded
to the trunion in production versions of the weapon.
Additionally, the bottom plate will be welded to each
side plate.

Based on the above examination, the sample as
submitted is classified as a firearm as that term is
defined in 18 U.S.C., Chapter 44, section 921(A)(3).
Please be advised that this determination is based on
a firearm using a newly designed and manufactured
right side plate in the above described configuration.
If the design, dimensions, method or construction,
materials used or configuration are changed, this
classification is subject to review.







Mr. Curtis Debord


The sample is being returned under separate cover.

We trust that the foregoing has been responsive to
your inquiry. If we can be of any further assistance,
please contact us.

                   Sincerely yours,
                   Edward M. Owen, Jr.
            Chief, Firearms Technology Branch