DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226

                                                        JAN 2 0 1998

                                         F:SD:FTB:EMO
                                         3311

American Arms/Delta
1469 Greg Street
Sparks, Nevada 89431

Gentlemen:

This refers to your letter of December 16, 1997, with
which you submitted a sample of a semiautomatic weapon
based on the Browning Model 1919 machinegun design you
desire to manufacture.

Examination of the submitted sample, serial number
AM0001, indicates that it is a firearm based on the
Browning Model 1919 machinegun. The receiver has been
constructed utilizing a standard Model 1919 machinegun
trunion, bottom plate, top plate, left side plate, and
back plate. A new right side plate approximately .065
inches thicker than a Model 1919 machinegun side plate
has been fabricated and assembled to the above
mentioned components. This side plate has been slotted
to permit assembly and function with a redesigned
Browning Model 1919 barrel extension, lock frame and
bolt.

The trigger has been redesigned to permit only a single
shot to be fired each time the trigger is pulled. The
redesigned trigger also incorporates a trigger return
spring and the forward engagement surface and trigger
arm width have been constructed such that they are not
compatible with a standard Model 1919 sear plate. The
forward portion of the trigger arm is spring loaded to
act as a disconnector. A new sear plate has been
fabricated that is wider than standard. Additionally,
the trigger engagement area of the sear plate has been
designed such that the trigger will not reengage the
sear plate unless the trigger is released after each
shot is fired.

The rear of the bolt has been machined to accept the
above described sear plate. This machining prevents
the installation of a standard Model 1919 sear plate.

-2-

American Arms/Delta

The right side of the bolt has had two lengthwise
grooves machined to a depth of approximately.062 and
.115 inches. These grooves permit assembly and
function in the redesigned receiver.

The rear spacer in the lock frame has been modified by
the addition of a screw used to mount the trigger
return spring and also act as a trigger travel stop.
This spacer is welded in place. The right side of the
lock frame has been grooved to a depth of approximately
.0972 inches for a length of approximately 3.422 inches
to permit assembly and function in the redesigned
receiver. The accelerator has been machined to allow
clearance for the redesigned trigger arm.

The right side of the barrel extension has been grooved
in two areas to a depth of approximately .064 inches to
permit assembly and function in the redesigned
receiver. The rear of the barrel extension has been
relieved to permit clearance of the forward portion of
the trigger arm. A cross bolt type safety has been
added to the outside of the backplate.

The above internal component configurations and
modifications can be used in producing a semiautomatic
weapon based on the Model 1919 machinegun design,
provided that the redesigned right side plate is
permanently attached to the trunion, bottom plate and
top plate by means of deep penetrating, full fusion,
gas or electric steel seam welds.

Please be advised that this determination is based on
the sample as submitted. If the design, dimensions,
material used, configuration or method of construction
are changed, this classification is subject to review.
Additionally, this determination applies only to the
firearm in question being manufactured in the United
States. We would point out that the firearm likely
would not qualify for importation under the provisions
of 18 U.S.C. S 925(d)(3). As a result, the receiver
for the weapon in question could not be imported.

The sample is being returned under separate cover.

-3-

American Arms/Delta

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

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