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What's the chances this would be Non-restricted. It takes an AR upper ?
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it'll be labeled as an AR varient.

Most likely.

I can see the argument that the receiver is a novel design, but the fact that it takes a standard AR upper (even though it requires a proprietary BCG) sinks hopes of a NR status. Although, a friendly firearms classification committee could decide it's not an AR variant...
 
Any thing that can even have an AR upper duct taped to it and even make it go bang once is a AR varient.

Just look at TV-PressPass' MKA 1919. Its not even close, but its an AR.

The Armi Jager AP74 is also an AR15 variant, despite having a 0% parts interchangeability with the AR15 platform.

The Armi Jager is a named variant. As for the MKA 1919, the decision to classify it as an AR variant is questionable at best, and IMO we can use these ridiculous classification decisions to show that the term "unnamed variant" is unconstitutionally vague.
 
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