22LR ATF Document

This is in response to your correspondence to the Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF), Firearms Technology Industry Services Branch (FTISB), which accompanied
your submitted sample of one hand-crank Gatling gun. Specifically, you requested an evaluation
and classification under the Gun Control Act of 1968 (GCA), 18 U.S.C. § 921(a)(3), and the
National Firearms Act (NFA), 18 U.S.C. § 5845(a).
Tippmann Armory, model Gatling Gun, .22LR caliber, hand-cranked firearm,

serial number 0001

During testing and evaluation, FTISB determined the Tippmann Armory, model Gatling Gun,
as submitted in this configuration does not fall under the purview of the NFA. The sample is a
“firearm” as defined in the GCA, 18 U.S.C. § 921(a)(3).

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Mr. Bradley J. Tippmann 322018
Background:
The GCA, 18 U.S.C. § 921(a)(3), defines the term “firearm” as: “(A) any weapon (including a
starter gun) which will or is designed to or may readily be converted to expel a projectile by the
action of an explosive; (B) the frame or receiver of any such weapon; (C) any firearm muffler or
firearm silencer; or (D) any destructive device. Such term does not include an antique firearm.”
The NFA, 26 U.S.C. § 5845(a), defines “firearm” in part as: “(5) any other weapon, as defined
in subsection (e); ...[and]...(6) a machinegun;...”
The NFA, 26 U.S.C. § 5845(b) defines “machinegun” as: “...any weapon which shoots, is
designed to shoot, or can be readily restored to shoot, automatically more than one shot, without
manual reloading, by a single function of the trigger. The term shall also include the frame or
receiver of any such weapon, any part designed and intended solely and exclusively, or
combination of parts designed and intended, for use in converting a weapon into a machinegun,
and any combination of parts from which a machinegun can be assembled if such parts are in
the possession or under the control of a person.”
The NFA, 26 U.S.C. § 5845(e), defines the term “any other weapon” to mean: “...any weapon
or device capable of being concealed on the person from which a shot can be discharged
through the energy of an explosive, a pistol or revolver having a barrel with a smooth bore
designed or redesigned to fire a fixed shotgun shell, weapons with combination shotgun and rifle
barrels 12 inches or more, less than 18 inches in length, from which only a single discharge can
be made from either barrel without manual reloading, and shall include any such weapon which
may be readily restored to fire. Such term shall not include a pistol or a revolver having a rifled
bore, or rifled bores, or weapons designed, made, or intended to be fired from the shoulder and
not capable of firing fixed ammunition.”
ATF Ruling 2004-5 states: “The original Gatling Gun is a rapid-firing, hand-operated weapon.
The rate of fire is regulated by the rapidity of the hand-cranking movement, manually controlled
by the operator. It is not a “machinegun” as that term is defined in 26 U.S.C. 5845(b) because it
is not a weapon that fires automatically.”
Evaluation:
FTISB personnel found that the submitted sample, Tippmann Armory, model Gatling Gun,
has the following features and characteristics:
• The overall length is approximately 20 inches.
• The receiver housing construction is aluminum as determined by XRF analyzer.
• The sample has a weight of approximately 15 pounds.
• The barrel length is approximately 8-1/2 inches (rifled bore barrel.)

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Mr. Bradley J. Tippmann 322018
Further, FTISB found the following markings:
Receiver (left side): Tippmann Armory [Manufacturer]

Gatling Gun [Model]
S/N 0001 [serial number]
Ft. Wayne, IN [City, State of Manufacturer]
Pat. Pending

Tripod (rear) TIPPMANN ARMORY [Manufacturer]
FORT WAYNE, IN [City, State of Manufacturer]
.22 CAL. [Caliber]
GATLING GUN [Model]

FTISB observed the submitted sample to fit all parameters of a Gatling-type gun, consistent with
ATF Ruling 2004-5. Characteristically, a Gatling gun is a rapid-firing, hand-operated weapon
having a bore diameter of .50 caliber or less and as produced under the patents of 1862-1893,
employing a cam action to accomplish the functions of repeat cocking and of firing and ejecting
ammunition of a caliber that is commercially available. With a date of manufacture being after
1898, this Gatling gun would be classified as a “firearm.”
However, if the submitted sample were to be modified or altered to use an externally driven
motor as an operating mechanism, this would change the classification to not only a “firearm”
but also a “machinegun” as defined in the NFA. That is why externally driven machineguns
such as the M-134 minigun are “firearms” and “machineguns” subject to NFA controls (see
ATF Ruling 2004-5).

Tippmann Armory, model Gatling Gun manual hand-crank

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Mr. Bradley J. Tippmann 322018
FTISB notated during evaluation that the tripod has been designed and constructed with three
rigid non-folding legs, non-removable shoes, and a blind riveted pintle assembly. All points of
attachment appeared to use the blind rivet method. A blind rivet is a rivet that can be completely
installed from one side, unlike machine screws and nuts, which requires access to both sides of
the material. A blind rivet consists of two pieces that are pre-assembled: the rivet and setting
mandrel.
FTISB has previously determined that this method of attachment is sufficient to consider the
firearm receiver permanently affixed to the pintle and pintle to the tripod. It should be noted, if
the tripod was modified to collapse or replaced with a folding type of platform, this would
drastically change the overall size and bulk of the sample making it easier to conceal on a person
and changing the classification to not only a “firearm,” but also an “any other weapon” as
defined in the NFA.

Tippmann Armory, model Gatling Gun rigid non-folding legs
Conclusion:
During testing and evaluation, FTISB determined the Tippmann Armory, model Gatling Gun,
as submitted in this configuration does not fall under the purview of the NFA. The sample is a
“firearm” as defined in the GCA, 18 U.S.C. § 921(a)(3).
These findings are based on the sample as submitted. If the design, dimensions, configuration,
method of operation, or materials used were changed, our determination would be subject to
review.
The submitted sample will be returned under separate cover.

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Mr. Bradley J. Tippmann 322018
FTISB trusts that the foregoing has been responsive to your request for an evaluation. If we can
be of any further assistance, please contact us.

Sincerely yours,

Daniel Hoffman

Chief, Firearms Technology Industry Services Branch
Cc: Daryl McCormick, Special Agent in Charge, Columbus Field Division
Judyth LeDoux, Director, Industry Operations, Columbus Field Division