Defense Distributed v. Bondi

July 14, 2025

On Friday Defense Distributed filed our reply to the ATF’s objection to our motion for an injunction against the Biden/Trump “frame or receiver” rule. It’s a Trump rule now not just because his DOJ defends it, but because it gives the rule novel interpretations never attempted in the Biden years.

This filing was more enjoyable to prepare than usual because of the excuse to engage with the “history and tradition” of privately made arms demanded by Bruen. We work into the record two surveys of industrial history that became my favorites after Defense Distributed’s failed effort to sue California back in 2022. They are provided below.

This reply was also enjoyable for the chance to respond to ATF’s candid admission that their rule “modestly impinges” Second Amendment rights. The Bondi DOJ may soon realize this statement was worse than an infelicity.

Those two industrial histories for you. David Hounshell’s From the American System to Mass Production, 1800-1932 and Conservative Innovators and Military Small Arms: an Industrial History of the Springfield Armory, 1794-1968. You can’t find an historical, industrial analogue for the regulation of the private production of small arms in America because it was that very history of private production that built the American System in the first place.

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