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Thread: It Is Past Time For An Update On The Tenko

  1. #81
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    Sorry brother. Was just trying to make you smile tonight. Keep up the good fight.

  2. #82
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    Thank you. I did smile. The whole thing is just so bizarre. I very much appreciate the humor.

    Scott

    ETA, I am considering the next submission will be with a CMMG 9mm rotary delayed upper using the MEAN Arms incert system for mags. So the adapter would still have the same basic function of a M16 lower, but the submission would be 9mm with lower mass.
    Last edited by A&S Conversions; 02-13-2021 at 08:51 PM.

  3. #83
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    Good luck - hope you’re successful!
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  4. #84
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    Quote Originally Posted by rybread View Post
    Good luck - hope you’re successful!
    Thank you very much.

    Scott
    Manager A&S Conversions L.L.C.

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    I'm trying to untangle those words you posted from them. I'd love if we had a lawyer around to explain what they're trying to say.

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    Yeah that last part worries me a bit. I'd be careful poking the bear to much as they'll just immediately sent you'd stuff back rejecting it saying it's a redesign. If I understand correctly anything venturing to far from the original design is considered a redesign and is no long the same machine gun. Like taking a mac and cutting the serial number off and welding it to an AR lower. There were a few other items over the years I think fell into this category of "redesign". Wasn't that the issue with the Mac rpd and saw?

  7. #87
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    The RPD stuff was due to receiver recycling- but this seems to indicate Something beyond that I’m afraid if the sear functionality in the Mac is brought into the upper (not being too familiar with the Tenco design) and the interaction between the bolt and the sear is not direct, you’ve built another lower. All Lage designs are Derivatives of the stock Mac upper- Bolt and channel, plus a magwell. The FA sear in the lower operates the bolt. Again My understanding is The bolt in the Tenco operates off a mechanism that conveys the sear function to the bolt, and the ATF (Now) sees this as a functional lower. This can be designed around to make an AR upper adapter for a Mac but probably a big departure from the current design.
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  8. #88
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    My understanding is that that is a scare tactic. Basically, because we are adapting another firearm's mechanism to the M10, that would be considered "making" a new machinegun. Of course there is nothing in the law that Congress wrote to that effect. As far as I am concerned, that statement is a lie. But if saying so would deter us from resubmitting, then he has denied the submission before it was sent. If what he stated was true then any configuration that was not original submitted would be a new machinegun. So the long stroke piston or rotary delayed blowback uppers would make a transferable M16 a new machinegun.

    The toughest part of this whole ordeal for me is my Government out right lied to me. They keep repeating that they never shot the first submission. Again I think that is a bold faced lie. I never fired the original submission before sending it. I did check the timing (there is a how to check the timing of a M16 on Quarter bore's site) before I sent it in.

    When I received the 3D printed version back, it had gunpowder residue from being fired on it. Since I expected them to fire it, I never thought to document the residue. We went on to test it with over 5,000 rounds of 5.56X45. Now they say that they never fired the original submission because they were afraid that the 3D printed version would have a catastrophic failure. The adapter could be made from cardboard. The upper, specifically the bolt and the barrel are containing the gunpowder, not the adapter. It is my understanding that our form of Government is supposed to be based on the truth. We are supposed to trust our Government to deal with us openly and honestly. If they are not then we need to elect new officials that will be fair and honest. I hate that my Government is choosing to lie to me for a political purpose rather than enforcing the law without passion or prejudice.

    Scott

  9. #89
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    Quote Originally Posted by Hood886 View Post
    Yeah that last part worries me a bit. I'd be careful poking the bear to much as they'll just immediately sent you'd stuff back rejecting it saying it's a redesign. If I understand correctly anything venturing to far from the original design is considered a redesign and is no long the same machine gun. Like taking a mac and cutting the serial number off and welding it to an AR lower. There were a few other items over the years I think fell into this category of "redesign". Wasn't that the issue with the Mac rpd and saw?
    But a "redesign" is not in the law as far as I have found. Please post a link to the section that states as such. I have looked and I have asked a NFA specific lawyer. It is something that the FATD invented because that is what they would like to be true. Obviously they don't have a problem misstating the law if it furthers their point. But like a bump stock is a machinegun, it is something that they dreamed up to further their current agenda.

    As far as the RPD & SAW uppers, it is my understanding that that the original manufacturer demilled the receivers of the original machineguns, rewelded the receivers back together, then modified the receivers into "uppers". My understanding of the process is if the receiver peices being rewelded would become a machinegun receiver. The modifications would need to be done before the peices are welded back together so the peices never form a completed machinegun receiver. The easiest way would be to make the "upper " from parts were never a firearm in the first place.

    As far as the Tenko mechanism, all fire control is mounted in the registered part (the M10 lower) and is activated by the sear. As far as I know the only actual restrictions on modifications by law is on the register part. In this case that would be the M10 receiver channel. Modifying the receiver channel too much would be considered a redesign. The Tenko adapter is mounted to a registered part via the front pin, just as factory upper. The mechanism (the recoil spring) bears on the inside of the rear of the receiver channel, just like the factory upper. And the fire control (specifically the hammer which is mentioned in the definition of firearm) is also mounted into the registered part and is activated by the M10 sear like the factory original. Does it function like the factory original? No, but that is not what the law says.

    Scott
    Manager A&S Conversions L.L.C.

    ETA, cutting off the serial number and welding that peice onto another receiver is too much modification to the original registered receiver machinegun receiver. Some manufacturers have written to the FATD as to modification of a transferable receiver and retaining transferable status. The modifications to a STEN tube to use with the Sterling mechanism. I have heard such a Sterling referred to as a "Stenling".
    Last edited by A&S Conversions; 02-14-2021 at 10:14 AM.

  10. #90
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    Why not wait and see if Lage gets approved for their m10 and m11 uppers? They’ve been waiting for a long time already and keep moving the time frame back. I think he said at one point, after covid the examiners will be back and be able to review the samples; Then they should get a determination. That could be never or a decade the way the gov is going about the chiNAH virus.

    I know yours is totally different but if they don’t approve the Lage uppers, then there’s no point in submitting yours because you’ll no the atf is screwing every body over, not just you. If Lage wants to fight it, I’m guessing he’s got the Capitol to do it. If he goes that rout and wins, maybe you could jump on the band wagon then. Just a thought.




    I’m assuming by your first post that you got this determination letter a while ago.

  11. #91
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    Yes you are right, our product is very different from the Lage. We are on different paths. We are looking to move forward.

    Scott

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    Would it be possible to design a trigger and hammer mechanism ala AR15 to replace the macs current fire control group. Then you could make the upper a closed bolt system. Would make it virtually impossible to rig it up to fire full auto and I don’t see how it would be any different then changing the fire control group in an AR15 to burst, 4 position etc.

  13. #93
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    Quote Originally Posted by Uniquesnd View Post
    Would it be possible to design a trigger and hammer mechanism ala AR15 to replace the macs current fire control group. Then you could make the upper a closed bolt system. Would make it virtually impossible to rig it up to fire full auto and I don’t see how it would be any different then changing the fire control group in an AR15 to burst, 4 position etc.
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  14. #94
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    Yeah I completely agree it's a bunch of BS and there are no laws making things clear but instead we just have to guess what the atf wants and they can change their minds are any minute.

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    I am a big supporter of the Tenko and other designs that are in the works. And I have tried to be positive. I really want these to come to markets. Unfortunately I don't think the BATFE will ever approve an upper or adapter that does not maintain the open bolt firing design of the MAC. Converting to a closed bolt will be viewed as a "redesign" and thus an illegal machinegun. There is no basis in law for the firearms branch to do this, it is just my uneducated guess as to what they will do. Federal agencies are charged with implementing law. They don't write the law, but the courts give them a lot of latitude in how they interpret it. The Chevron doctrine essentially states that agencies that are responsible for interpreting law, are better situated to interpret law than the industry experts who have to live with their decision. So agency decisions that are not absolutely contrary to written law will prevail in court no matter how stupid the logic. Scott, I really do wish you the best of luck and hope you can make the redesign of your adapter get past the trolls and be approved.

  16. #96
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    Quote Originally Posted by nklf View Post
    I am a big supporter of the Tenko and other designs that are in the works. And I have tried to be positive. I really want these to come to markets. Unfortunately I don't think the BATFE will ever approve an upper or adapter that does not maintain the open bolt firing design of the MAC. Converting to a closed bolt will be viewed as a "redesign" and thus an illegal machinegun. There is no basis in law for the firearms branch to do this, it is just my uneducated guess as to what they will do. Federal agencies are charged with implementing law. They don't write the law, but the courts give them a lot of latitude in how they interpret it. The Chevron doctrine essentially states that agencies that are responsible for interpreting law, are better situated to interpret law than the industry experts who have to live with their decision. So agency decisions that are not absolutely contrary to written law will prevail in court no matter how stupid the logic. Scott, I really do wish you the best of luck and hope you can make the redesign of your adapter get past the trolls and be approved.
    You certainly have some valid points. If this were the first submission the FATD might be able to "hang their hat" on this is a "redesign". But they approved the first submission, supposedly without firing it. In the second determination of the aluminum version they said that the Tenko with an AR-15/M16 upper was a machinegun because they got the Tenko with the AR upper to fire seven rounds automatically. There was no mention of "redesign" in the second determination. We are working on measures that require the Tenko to be installed in a M10 in order to fire automatically. But those mechanical measures to inhibit firing without the M10 lower don't change the basic function of how the adapter works.

    So it would seem to me, if the third submission is denied as a "redesign", how can they justify no mention of a "redesign" in the previous two submissions? I am not so naive as to imagine that the FATD would not try is ploy. A letter is normally enclosed with the submission. I plan to address this very issue in the first paragraph of the letter accompanying the next submission. We spent a great deal of money developing the aluminum version between the first and second determinations. They say that they didn't do their job with the first determination, but the second determination was correct. Adding yet another "hoop" for us to jump through, would be them, again not doing their job with the second determination and again injuring us.

    I can't predict what the FATD will do. The engineer has come up with several ideas to modify the design such that it will be very difficult to make the Tenko fire without the M10 lower. Any mechanical measure could be defeated. I guess the question is how involved are they going to get to defeat the multiple measures we are planning to install? And how much would those measures to defeat our measures will look like a M10 lower receiver? We will do our best and then resubmit. It would certainly seem to me that they want me to give up. Someday I might. But that day is not today.

    Scott
    Manager A&S Conversions L.L.C.
    Last edited by A&S Conversions; 02-15-2021 at 07:48 AM.

  17. #97
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    “It would certainly seem to me that they want me to give up. Someday I might. But that day is not today.”

    Great attitude & entrepreneurial spirit!!!
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    Quote Originally Posted by A&S Conversions View Post
    As far as the Tenko mechanism, all fire control is mounted in the registered part (the M10 lower) and is activated by the sear. And the fire control (specifically the hammer which is mentioned in the definition of firearm) is also mounted into the registered part and is activated by the M10 sear like the factory original.

    It’s interesting that it could fire without the hammer, which you say is in the M10 lower.


    I know you don’t talk about specifics of the Tenko firing mechanism but is that correct? The hammer is mounted in the lower and removing the lower from the Tenko also removes the hammer from the Tenko?

  19. #99
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    Quote Originally Posted by TSPC View Post
    It’s interesting that it could fire without the hammer, which you say is in the M10 lower.


    I know you don’t talk about specifics of the Tenko firing mechanism but is that correct? The hammer is mounted in the lower and removing the lower from the Tenko also removes the hammer from the Tenko?
    Yes, that is correct. I am sorry that I can't give more detail. When we can go to market we will be able to go into detail.

    Scott
    Manager A&S Conversions L.L.C.

  20. #100
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    Quote Originally Posted by A&S Conversions View Post
    Yes, that is correct. I am sorry that I can't give more detail. When we can go to market we will be able to go into detail.

    Scott
    Manager A&S Conversions L.L.C.

    From an engineering view, and assuming no trickery from the examiners, it could be argued that a CLOSED bolt system should not be able to fire with its hammer removed, with or without a receiver installed, and the Tenko may have a fundamental design flaw. That may sound harsh but it would actually mean it’s an engineering issue that can potentially be corrected.

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