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CCRKBA URGES WA GUN OWNERS TO OPPOSE GUN BAN LEGISLATION; HEARING TUESDAY JAN. 26

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CCRKBA URGES WA GUN OWNERS TO OPPOSE GUN BAN LEGISLATION; HEARING TUESDAY JAN. 26
BELLEVUE, WA – Evergreen State gun owners are urged to contact their state senator, and if possible, plan to attend a hearing on Senate Bill 6396, the proposed ban on so-called “assault weapons” sponsored by Senators Adam Kline and Jeanne Kohl-Welles.

The public hearing is scheduled Tuesday, Jan. 26 at 10 a.m. in Hearing Room 1 of the John A. Cherberg Senate Office building, the Citizens Committee for the Right to Keep and Bear Arms learned Thursday.

“This is an unnecessary, and frankly useless, proposal that is aimed at the wrong people, and will accomplish nothing to reduce crime or prevent tragedies such as the murder of four Lakewood police officers last November,” said CCRKBA Legislative Director Joe Waldron. “It is important for all Washington State gun owners to contact their state senator on this issue.”

Waldron noted that the Legislative Hotline number is 1-800-562-6000.

“Messages to state senators should be brief, polite and on point,” Waldron added. “Gun owners should remind members of the Senate that none of the six police officers fatally shot in the line of duty last year were killed with a so-called ‘assault weapon.’

“Worse, still,” he continued, “are provisions that would allow warrantless searches of a citizen’s home to determine whether their semiautomatic sport-utility rifles are being properly stored. While there are no registration requirements in this bill, one is left to wonder how sheriff’s deputies would know which homes to visit without some roster of gun owners.

“This is an insidious proposal,” Waldron concluded, “that smacks of ‘first-step’ theatrics. The ultimate goal of the bill’s sponsors is to register, and eventually eliminate, ownership of sport-utility rifles. Gun owners should stop this now.”

With more than 650,000 members and supporters nationwide, the Citizens Committee for the Right to Keep and Bear Arms is one of the nation’s premier gun rights organizations. As a non-profit organization, the Citizens Committee is dedicated to preserving firearms freedoms through active lobbying of elected officials and facilitating grass-roots organization of gun rights activists in local communities throughout the United States. The Citizens Committee can be reached by phone at (425) 454-4911, on the Internet at www.ccrkba.org or by email to InformationRequest@ccrkba.org.

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Copyright © 2010 Citizens Committee for the Right to Keep and Bear Arms, All Rights Reserved.

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FEDS RESPOND TO FIREARMS FREEDOM ACT LAWSUIT MOTION TO DISMISS “EXPECTED”

MISSOULA – The United States has made its first response to a lawsuit filed in federal district court in Missoula to test the Montana Firearms Freedom Act (MFFA), passed by the 2009 Legislature and signed into law by Governor Schweitzer.

The MFFA declares that any firearms, ammunition or firearms accessories made and retained in Montana are not subject to federal regulation under the power given to Congress in the U.S. Constitution to regulate commerce “among the several states.” The MFFA is a states’ rights challenge on Tenth Amendment grounds, with firearms serving as the vehicle for the challenge.

This lawsuit to validate the MFFA was brought by the Montana Shooting Sports Association (MSSA) and Second Amendment Foundation (SAF). The suit names U.S. Attorney General Eric Holder as defendant, and is referred to as MSSA v. Holder.

The first response to the lawsuit by the United States is a Motion to Dismiss, submitted January 19th and considered to be a standard procedural maneuver in lawsuits against the U.S government . This motion seeks to avoid the legal merits by asserting that the Plaintiffs lack standing to sue, that a justiciable controversy does not exist, and that prevailing case law is against Plaintiffs.

MSSA President Gary Marbut, also a Plaintiff in the lawsuit explained, “The first import of this response is that the legal game is now on. There was some concern that the defendants would forfeit the game with no response in an effort to prevent this important issue from being adjudicated properly. We are now beyond that hurdle.” However, the Motion to Dismiss by Washington also seeks to sidestep proper adjudication.

SAF Founder Alan Gottlieb said, “We are disappointed but not surprised that the government would try to kill this suit on standing, rather than arguing about the merits of the case.”

The MFFA concept has gained traction across the Nation since its passage in Montana. Tennessee has enacted a clone of the MFFA, and other clones have been introduced in the state legislatures of 19 other states, including: Alabama, Alaska, Arizona Florida, Georgia, Indiana, Kentucky, Michigan, Minnesota, Missouri, New Hampshire, Ohio, Oklahoma, Pennsylvania, South Carolina, Texas, Utah, Virginia, Washington, and Wyoming. . Ten or more additional states are expected to introduce yet more MFFA clones in the next few weeks. (See: http://www.FirearmsFreedomAct.com)

The U.S.’s Motion to Dismiss and Brief in Support are viewable at: http://FirearmsFreedomAct.com/montana-lawsuit-updates/

MSSA and SAF have assembled a litigation team for this effort consisting of three attorneys from Montana, one from New York, one from Florida and one from Arizona. Lead attorney for the Plaintiffs is Quentin Rhoades, partner the Missoula firm of Sullivan, Tabaracci and Rhoades. Other interested parties from both in and out of Montana are preparing to weigh in on this issue of national interest and national importance as amicus curiae (friends of the court).

Marbut commented, “The FFA concept has created a firestorm of interest nationwide. Lots of people and other states are watching carefully to see how Montana fares in this challenge to overbearing federal authority and to Washington’s attempt to control every detail of commerce in the Nation, especially including activity wholly confined within an individual state. That level of micro management certainly was not the intent of our founders when they gave Congress limited power in the Constitution to regulate commerce ‘among the states’.” (See: http://FirearmsFreedomAct.com/what-is-the-commerce-clause/)

MSSA is the primary political advocate for gun owners and hunters in Montana, having gotten 54 pro-gun and pro-hunting bills through the Montana Legislature in the past 25 years. SAF is a pro-gun foundation in Bellevue, Washington, established to press the rights of gun owners primarily in judicial fora. SAF has been a party to numerous lawsuits to assert the rights of gun owners across the Nation.

The Second Amendment Foundation (www.saf.org) is the nations oldest and largest tax-exempt education, research, publishing and legal action group focusing on the Constitutional right and heritage to privately own and possess firearms. Founded in 1974, The Foundation has grown to more than 650,000 members and supporters and conducts many programs designed to better inform the public about the consequences of gun control. SAF has previously funded successful firearms-related suits against the cities of Los Angeles; New Haven, CT; and San Francisco on behalf of American gun owners, a lawsuit against the cities suing gun makers and an amicus brief and fund for the Emerson case holding the Second Amendment as an individual right.

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Copyright © 2010 Second Amendment Foundation, All Rights Reserved.

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Gun Owners Buy 14 Million Plus Guns In 2009 – More Than 21 of the Worlds Standing Armies

Wednesday, January 13th, 2010 at 11:43 am
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USA Gun Owners Buy 14 Million Plus Guns In 2009 – More Than 21 of the Worlds Standing Armies Combined
That is 14,033,824,000 billion+ rounds of Ammo..you think that is why we have an Ammo shortage?

Total NICS Gun Buyer Background Checks 2009Total NICS Gun Buyer Background Checks 2009

AmmoLand Gun News

Washington, DC –-(AmmoLand.com)- Data released by the FBI’s National Instant Criminal Background Check System (NICS) for the year reported 14,033,824 NICS Checks for the year of 2009, a 10 percent increase in gun purchases from the 12,709,023 reported in 2008.

So far that is roughly 14,000,000+ guns bought last year!
The total is probably more as many NICS background checks cover the purchase of more than one gun at a time by individuals.

To put it in perspective that is more guns than the combined active armies of the top 21 countries in the world. countries by number of troops

Of the NICS background checks preformed less than and average .005% were denied, showing, overwhelmingly, that law abiding American citizens are the ones buying guns and that criminals are getting their guns elsewhere.

14,033,824,000 billions rounds of Ammo
Assuming each gun buyer bought 1000 rounds of ammo for each purchase, and you and I know that it is way, way more than that, that would be easily 14,033,824,000+ billions rounds of ammo fired by USA gun owners.

What percent of people were killed or injured by this ammo…it is just to infinitesimally small for me to calculate?

Crime At Record Lows
This record year in firearms background checks show that Americans are solidly in-favor of exercising their civil right to Keep and Bear Arms.

In a year were crime has reached an all time record low what is plainly clear is that more guns equal LESS CRIME!

Countries By Number Of Troops: Source Wikipedia

People’s Republic of China 2,255,000
United States 1,473,900
India 1,414,000
North Korea 1,106,000
Russia 1,037,000
Pakistan 619,000
South Korea 687,000
Iran 545,000
Turkey 514,850
Vietnam 484,000
Egypt 450,000
Myanmar 428,250
Indonesia 400,000
Brazil 369,000
Thailand 306,600
Syria 296,000
Republic of China 290,000
Colombia 285,554
Germany 284,500
Iraq 273,618
Sri Lanka 266,700
13,785,972
People’s Republic of China 2,255,000
United States 1,473,900
India 1,414,000
North Korea 1,106,000
Russia 1,037,000
Pakistan 619,000
South Korea 687,000
Iran 545,000
Turkey 514,850
Vietnam 484,000
Egypt 450,000
Myanmar 428,250
Indonesia 400,000
Brazil 369,000
Thailand 306,600
Syria 296,000
Republic of China 290,000
Colombia 285,554
Germany 284,500
Iraq 273,618
Sri Lanka 266,700

This is an evaluation of overall firearms and ammunition purchases based on low end numbers per Federal NIC instacheck data base Statistics. The numbers presented are only PART of the overall numbers of arms and ammunition that have been sold.

The actual numbers are much higher.

Firearms Manufactures Working Hard To Keep UpFirearms Manufactures Working Hard To Keep Up

Distributed to you by AmmoLand.com – The Shooting Sports News source.
People’s Republic of China 2,255,000
United States 1,473,900
India 1,414,000
North Korea 1,106,000
Russia 1,037,000
Pakistan 619,000
South Korea 687,000
Iran 545,000
Turkey 514,850
Vietnam 484,000
Egypt 450,000
Myanmar 428,250
Indonesia 400,000
Brazil 369,000
Thailand 306,600
Syria 296,000
Republic of China 290,000
Colombia 285,554
Germany 284,500
Iraq 273,618
Sri Lanka 266,700
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Dont forget next weekend (January 29-31st) Michigan Hunting Expo

Michigan Hunting Shows and Expos

HUNTIN’ TIME EXPO 2010

Our 19th aniversary of celebrating the 2nd Amendment and hunting, in the United States!


Why travel all over the country when you can target your efforts in the largest hunting market in the world? The Huntin’ Time Expo offers you this incredible market January 29-31, 2010 in Grand Rapids! This all-hunting show is geared for serious hard-core hunters not “tire kickers”. Come join in the fun and see what the excitement is all about!

The Delta Plex is located off US 131, one mile north of downtown Grand Rapids. This excellent location conveniently delivers hunters from Grand Rapids, Muskegon, Holland, Grand Haven, Kalamazoo and others WITHOUT experiencing traffic, parking and load-in headaches.

Grand Rapids is one of the top 10 fastest
growing cities in the country!

The Delta Plex offers offers over 80,000 square feet of MAIN FLOOR exhibitor space making The Huntin’ Time Expo West, the largest ALL HUNTING show in the state! (FREE WEEKEND PARKING!)

Huntin’ Time Expo West show dates and times

January 29-31, 2010
Delta Plex Arena
Grand Rapids, MI
January 29 2 PM – 9 PM
January 30 9 AM – 7 PM
January 31 10 AM – 5 PM
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McDonald vs. The City of Chicago.

Will Your Gun Rights Live or Die?

By Kirby Ferris
Jews for the Preservation of Firearms Ownership
.

Copyright JPFO 2010

Coming up in our lives is perhaps the most critical Supreme Court decision in a century. Sometime towards summer of this year the Supreme Court of the United States (SCOTUS) is going to decide on the case McDonald vs. The City of Chicago. Oral arguments begin March 2nd. The implications are immense.

A favorable ruling for McDonald would overthrow the Chicago ban on handgun ownership and would open the floodgates for an immense wave of (likely successful) pro-gun lawsuits against American cities, counties, and States.

Second Amendment advocates felt that a win in the Heller decision was vitally important for gun owners (JPFO filed a “friend of the court” brief in Heller). Well, McDonald is Heller on steroids.

McDonald is Heller on steroids.

A victory for gun owners could profoundly change the face of our nation. State by State by State, gun prohibitionists could finally be rousted out and smashed into impotence. Remember that Heller only dealt with guns in the District of Columbia. Let us remind ourselves: D.C. is not a State.

JPFO has also filed a “friend of the court” brief on McDonald. Go here to read the brief in full. The ramifications of this ruling could either impact the Second Amendment for the better … or for the absolute worst.

What McDonald does is attempt to persuade the Supreme Court to bring the Second Amendment under the “protection” of the 14th Amendment. This is called “incorporation” in legalese.

Here is the immediately relevant portion of the 14th Amendment:

Section 1. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

SCOTUS has opined, over decades of decisions, that, because of the 14th Amendment, the States must obey the First Amendment. The high court has also found the same for the Fourth and Fifth Amendments, as well as other specific sections of the Bill of Rights.

… the States must obey the First Amendment.

However, until the Heller case, SCOTUS, since 1939, had literally kept 2A off the table, an untouchable “States Rights” issue. But Heller forced 2A right up to the front burner. The Supreme Court rather obviously had to pay attention to Heller, as D.C. is its immediate jurisdiction. So many pro-gun strategists see Heller as the “wedge” needed to open to door to McDonald.

But, as with all things legal, there are some unsettling ramifications. McDonald would undeniably give added power to the Federal government. No increase in federal power has ever benefited gun ownership. One need look no further than the “Gun Control Act of 1968” and the BATFE, with its draconian registration and “tracing” schemes, to understand this reality.

No increase in federal power has ever benefited gun ownership.

But in McDonald, it would seem, this added federal power, because it would add support to the individual right to gun ownership, would most likely be a positive thing. After all, freedom of speech and freedom of religion in all the States have actually been nurtured (or at least certainly not hindered) by “incorporation” under the 14th Amendment.

It seems a relatively safe bet that States with existing pro-gun stances would not be restricted by a positive McDonald decision. Or so we assume.

What is obvious is that the gun prohibitionists do not like what they see coming down the pike with McDonald. Are they hoping for a miracle?

Are they hoping for a miracle?

What could happen between now and the end of March to toss McDonald into disarray? Several events come to mind:

1. What if a horrific “lone gunman” massacre takes place?

Remember, both Australia and New Zealand reacted hysterically against gun ownership under such circumstances. And don’t ever forget that Patrick Purdy’s schoolyard slaughter in Stockton, CA was the emotional fuel that launched the so-called “Assault Weapons Ban”.

Could such another appalling event result in the inclusion of “weasel clauses” in the language of a McDonald verdict, or even a complete victory for gun prohibitionists?

Look to the pitifully anti-gun Anti Defamation League for an indication of how such a horrific (yet convenient) tragedy might be scripted.

The ADL is shrill in its concern about “white supremacists”. Therefore look for a “lone gunman”  to be white. For the “shock and awe” psychological effect to be truly wrenching, the unarmed victims will have to be either blacks … or Jews. The ADL and its ilk desperately need to be able to wring their hands in perversely satisfied anguish and scream out: “We told you so! We told you so!” or…

2. What if one of the Justices who voted in favor of Heller (and can therefore be assumed to vote favorably in McDonald) was to die between now and March?

Heller was a five to four win. What if a “pro-gun” Supreme Court justice was to die, or be killed, before McDonald is decided? What if Barack Obama is then able to bring forth a rabidly anti-gun candidate as a replacement before McDonald is decided? Are there enough votes in the Senate to deny such an appointment? Don’t bet on it.

What if a “pro-gun” Supreme Court justice was to die, or be killed, before McDonald is decided?

3. What if a prominent politician, bureaucrat, spokesperson, or worshipped celebrity is reportedly killed by a “lone nut case”?

4. What if another terrorist attack occurs? Mass casualties would create the perfect excuse for martial law, and an end run around the Constitution, making any decisions by the Supreme Court irrelevant.

Anybody familiar with the American history of clandestine government and elite class (establishment) activities since WWII should not be shocked if any of the above mentioned scenarios occur.

Yes, friends of freedom, crucial times are upon us. Pay very close attention, and redouble your effort to save the Second Amendment. JPFO has plenty of “intellectual ammunition” on our site waiting for you to use, such as its ground breaking award winning films “2A Today for The USA” and “No Guns for Negroes“. Be sure also to visit the “Freedom Flyer” page for links to some of JPFO’s most important material.

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Proof: More guns = less crime


between the lines Joseph Farah



Proof: More guns = less crime


Posted: January 16, 2010
1:00 am Eastern

© 2010 

There it was. Good news on New Year’s Day on the front page of the Washington Post.

“Homicide totals in 2009 plummet in District, Prince George’s,” the headline read.

In a story that likely got lost amid the holiday revelry, the paper reported that the nation’s capital in 2009 experienced its lowest number of homicides in 45 years. In case you can’t do the math real quick, that previous year would be 1964.

And for those too young to remember, 1964 was pretty much the end of an era. It was before the riots, before the Vietnam War was seriously escalated to become a national dividing point, before the drug explosion.

So what happened in Washington, D.C., in 2009 that might account for such a dramatic decline in homicide deaths?

Hmmmmm. Let me see. Nothing comes to mind.

Oh, wait a minute! Wasn’t 2009 the first full year following the overturning of Washington’s gun ban by the Supreme Court in the Heller case?

Could that have something to do with it?

Will blue-helmeted U.N. personnel be knocking on your door demanding your firearms? Wayne LaPierre lays out the agenda to limit your rights in “The Global War on Your Guns”

Apparently the Washington Post newsroom didn’t think so. It was not even mentioned in the New Year’s Day story – not even as an afterthought. That should tell you something about the political culture and worldview in elite newsrooms of America’s major metropolitan newspapers.

But think about it!

Once again, we have more real-life evidence of the theory so well articulated by John R. Lott in his breakthrough book, “More Guns, Less Crime.”

Remember what was predicted by the naysayers following the Heller case?

They foresaw blood in the streets. They believed a sort of citywide Armageddon would ensue. They prophesied gloom and doom. In fact, even in his Supreme Court dissent, Justice Stephen Breyer argued the gun ban was necessary for public-safety reasons because “guns were ‘responsible for 69 deaths in this country each day.'”

What Breyer didn’t understand was that guns are not responsible for any deaths. People are. Bad guys are. Murderers are. And when those guys have a virtual monopoly on force, because law-abiding citizens can’t bear arms, that’s when blood flows in the streets.

For 20 years before the Heller decision, Washington was known alternately as the murder capital of the country and the “District of Criminals.”

But something happened to make 2009 different. There was a significant drop in violent crime and property crime. The sharpest drop was in homicides – 25 percent. There was a 16 percent drop in sexual assaults and a 10 percent decrease in car thefts.

Can anyone point to another factor?

Was it Barack Obama’s anointing presence? I don’t think so.

It was Heller.

By the way, you probably also heard the news that 2009 was a banner year for gun sales nationwide. Americans, in fear Obama and the Democrat-dominated Congress would move quickly to limit their ability to exercise their Second Amendment rights, went out and got guns while they could.

These folks braved the worst economic crisis since the Great Depression to go out and buy firearms, which are not cheap. They also bought ammunition, which is getting more expensive all the time.

And guess what resulted?

Were more people killed by guns as the gun-control freaks always predict?

Nope.

Just the opposite.

According to the FBI’s uniform crime report, law-enforcement agencies across the country experienced a decrease in violent crime for the first six months of 2009 from the same period the year earlier. Violent crime, which includes homicide, rape, robbery and aggravated assault, decreased by 4.4 percent. The complete annual report is not yet released.

But, mark my words, when it is out it will show violent crime down throughout America – because more people have guns.


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The Bushmaster ACR

http://www.bushmaster.com/acr/

Taking pre-orders now! contact kevin@tottss.com for quote and availability

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Breaking News: Federal Lawsuit Claims Remington ACR (Adaptive Combat Rifle) Violates RDMI (Alex Robinson of Robinson Armament) Patent

By David Crane
defrev (at) gmail (dot) com

January 15, 2010
Updated on 1/16/10

On January 4th, 2010, DefenseReview published a quick piece on the new “leaked” Remington ACR (Adaptive Combat Rifle) video. Well, something rather interesting has since occurred involving the ACR. According to RFC Express, a website covering “US Federal District Court, Recently Filed Cases”, a company designated as “RMDI, LLC” is listed as the Plaintiff in a federal lawsuit (Civil Action No. 2:10-cv-00029-DAK) vs. Defendant(s) Remington Arms Company, Inc., Bushmaster Firearms, Rock River Arms, and MagPul Industries. The “COMPLAINT FOR PATENT INFRINGEMENT” federal lawsuit was, according to RFC Express, just filed on Thursday, January 14, 2010 (yesterday) in a Utah District Court. Remington and Bushmaster are part of the Freedom Group, which is owned by Cerberus Capital Management, L.P.

RMDI, LLC is a limited liability company owned by Alex Robinson of Robinson Armament (ROBARM), maker of the XCR Modular Weapon System tactical rifle series. DefenseReview has been informed by Alex Robinson that the lawsuit involves a patent that Mr. Robinson has on an “ambidextrous magazine release (a.k.a. ambidextrous mag release) and bolt hold-open”, and that thefirearms involved in the alleged patent infringement/violation are the Remington ACR (previously known as the Bushmaster ACR) 5.56mm NATO (5.56×45mm NATO)/.223 Rem. tactical rifle, MagPul Masada ACWS (from which the ACR was derived and developed), Rock River Arms (RRA) LAR-8 7.62mm NATO (7.62mm NATO)/..308 Win. rifle, and the MagPul Massoud 7.62mm NATO/.308 Win. rifle. The official lawsuit document confirms this.

The official lawsuit document, which Defense Review has purchased and downloaded from the RFC Express website, states that the lawsuit is over U.S. Patent No. 7,596,900 (the “’900 patent”) entitled “Multi-Caliber Ambidextrously Controllable Firearm,” issued on October 6, 2009 to inventors Alexander J. Robinson, Darin G. Nebeker, and Jon C. Holway. It further states that “Defendants are liable for infringement of the ’900 Patent pursuant to 35 U.S.C. § 271.”

The lawsuit document continues:

“Upon information and belief, one or more of the Defendants’ acts of infringement
were made or will be made with knowledge of the ’900 Patent. Such acts constitute willful
infringement and make this case exceptional pursuant to 35 U.S.C. §§ 284 and 285 and entitle RMDI to enhanced damages and reasonable attorneys’ fees.”

There’s a Chinese saying “May you live in interesting times.” This situation should help make for an interesting SHOT Show 2010. Speaking of SHOT, you’ll be able to find Alex Robinson/Robinson Armament at the Serbu Firearms booth (#20034). Serbu makes the Serbu BFG-50 single-shot bolt-action .50 BMG rifle, Serbu BFG-50A mag-fed semi-auto .50 BMG tactical rifle, and Serbu SUPER-SHORTY 12-gauge tactical/combat shotgun.

Click here to view the original/official PDF version of the official lawsuit document.

The following is a copy of the federal lawsuit, in its entirety.

COMPLAINT FOR PATENT INFRINGEMENT Page -1-
JAMES B. BELSHE (USB No. 9826)
jbelshe@wnlaw.com
CLINTON E. DUKE (USB No. 9784)
cduke@wnlaw.com
AMBER B. LEAVITT (USB No. 11412)
aleavitt@wnlaw.com
WORKMAN | NYDEGGER
1000 Eagle Gate Tower
60 East South Temple
Salt Lake City, Utah 84111
Telephone: (801) 533-9800
Facsimile: (801) 328-1707
Attorneys for Plaintiff RMDI, LLC
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
CENTRAL DIVISION
RMDI, LLC, a Utah limited liability company,
Plaintiff,
v.
REMINGTON ARMS CO., INC., a North
Carolina corporation, BUSHMASTER
FIREARMS INT’L, LLC, a Maine limited
liability company, ROCK RIVER ARMS, INC.,
an Illinois corporation, and MAGPUL
INDUSTRIES CORP., a Colorado corporation,
Defendants.

Civil Action No. 2:10-cv-00029-DAK
COMPLAINT FOR PATENT
INFRINGEMENT
Honorable Judge Dale A. Kimball
RMDI, LLC (“RMDI”) brings this action against defendants Remington Arms Co., Inc.,
Bushmaster Firearms Int’l, LLC, Rock River Arms, Inc., and Magpul Industries Corp. (collectively
referred to hereafter as “Defendants”), and for good cause of action alleges as follows:
THE PARTIES
1. RMDI, LLC is a limited liability company organized under the laws of the State of
Utah with its principal place of business in North Salt Lake City, Utah.
COMPLAINT FOR PATENT INFRINGEMENT Page -2-
2. On information and belief, Remington Arms Co., Inc. (“Remington”) is a North
Carolina corporation with headquarters in Madison, North Carolina, has designated its registered
agent for purposes of service of process as CT Corporation System, 150 Fayetteville Street, Box
1011, Raleigh, North Carolina 27601, and is doing business in this judicial district.
3. On information and belief, Bushmaster Firearms Int’l, LLC (“Bushmaster”) is a
Maine limited liability company with headquarters in Windham, Maine, has designated its registered
agent for purposes of service of process as National Registered Agents, Inc., P.O. Box 509,
Readfield, Maine 04355, and is doing business in this judicial district.
4. On information and belief, Rock River Arms, Inc. (“Rock River Arms”) is an Illinois
corporation with headquarters in Colona, Illinois, has designated its registered agent for purposes of
service of process as Mark A. Larson, 1042 Cleveland Road, Colona, Illinois 61241, and is doing
business in this judicial district.
5. On information and belief, Magpul Industries Corp. (“Magpul”) is a Colorado
corporation with headquarters in Longmont, Colorado, has designated its registered agent for
purposes of service of process as Douglas Wayne Smith, 400 Young Court #1, Erie, Colorado
80516-8441, and is doing business in this judicial district.
JURISDICTION AND VENUE
6. This is an action for patent infringement arising under the provisions of the Patent
Laws of the United States of America, Title 35 of the United States Code.
7. Subject-matter jurisdiction over RMDI’s claims is conferred upon this Court by 28
U.S.C. §§ 1331 and 1338(a).
8. On information and belief, Defendants have solicited business in the State of Utah,
transacted business within the State of Utah and attempted to derive financial benefit from residents
COMPLAINT FOR PATENT INFRINGEMENT Page -3-
of the State of Utah, including benefits directly related to the instant patent infringement cause of
action set forth herein.
9. On information and belief, Defendants have placed their infringing products into the
stream of commerce throughout the United States, which products have been offered for sale, sold
and/or used in the State of Utah and/or in the District of Utah.
10. More specifically, on information and belief, Defendants have offered for sale and/or
sold their products through various retailers located in Utah, including, but not limited to,
Gallenson’s, Basin Sports, Good Gun Guys, Hammerback Guns, Kent Shooters Supply, Lee’s Gun
Shop, “Get Some” Guns & Ammo, Smith and Edwards, Big 5, and Cabela’s.
11. Defendants, directly or through their subsidiaries, divisions, groups or distributors
have committed acts of infringement in this judicial district, are subject to personal jurisdiction in
this judicial district, and/or are doing business in this judicial district.
12. Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and/or 1400.
ACCUSED PRODUCTS
13. Remington, directly or through its subsidiaries, divisions, groups or distributors,
makes, sells and/or offers for sale or allows others to make, use, sell and/or offer for sale infringing
products, including, but not limited to, the product identified as the Adaptive Combat Rifle, or ACR.
14. Bushmaster, directly or through its subsidiaries, divisions, groups or distributors,
makes, sells and/or offers for sale or allows others to make, use, sell and/or offer for sale infringing
products, including, but not limited to, the product identified as the Adaptive Combat Rifle, or ACR.
15. Rock River Arms, directly or through its subsidiaries, divisions, groups or
distributors, makes, sells and/or offers for sale or allows others to make, use, sell and/or offer for
sale infringing products, including, but not limited to, the product identified as the LAR-8.
COMPLAINT FOR PATENT INFRINGEMENT Page -4-
16. Magpul, directly or through its subsidiaries, divisions, groups or distributors, makes,
sells and/or offers for sale or allows others to make, use, sell and/or offer for sale infringing
products, including, but not limited to, the products identified as the Masada and the Massoud rifles.
17. Defendants’ products listed in paragraphs 13-16 above are collectively referred to
hereafter as “the Accused Products.”
18. The Accused Products do not necessarily represent an exhaustive list, and additional
products may be added pending further discovery.
CLAIM FOR RELIEF
PATENT INFRINGEMENT
19. On October 6, 2009, U.S. Patent No. 7,596,900 (the “’900 patent”) entitled “Multi-
Caliber Ambidextrously Controllable Firearm,” a copy of which is attached hereto as Exhibit A, was
duly and legally issued to the inventors Alexander J. Robinson, Darin G. Nebeker, and Jon C.
Holway.
20. RMDI is the owner by assignment of all right, title and interest in and to the ’900
patent, including the right to sue for and recover all past, present and future damages for
infringement of the ’900 patent.
21. Upon information and belief, Defendants, directly or through their subsidiaries,
divisions, groups or distributors, have infringed and continue to infringe the ’900 patent by making,
using, selling and/or offering to sell, or inducing or contributing to the infringement of the ’900
patent in the United States, including in the state of Utah, one or more of the Accused Products that
are covered by one or more of the claims of the ’900 Patent, including, but not limited to, claim 1 of
the ’900 Patent.
22. Defendants are liable for infringement of the ’900 Patent pursuant to 35 U.S.C. § 271.
COMPLAINT FOR PATENT INFRINGEMENT Page -5-
23. Defendants’ acts of infringement have caused damage to RMDI, and RMDI is
entitled to recover from the defendants the damages sustained by RMDI as a result of the
Defendants’ wrongful acts in an amount subject to proof at trial.
24. As a consequence of the infringement complained of herein, RMDI has been
irreparably damaged to an extent not yet determined and will continue to be irreparably damaged by
such acts in the future unless the defendants are enjoined by this Court from committing further acts
of infringement.
25. Upon information and belief, one or more of the Defendants’ acts of infringement
were made or will be made with knowledge of the ’900 Patent. Such acts constitute willful
infringement and make this case exceptional pursuant to 35 U.S.C. §§ 284 and 285 and entitle RMDI
to enhanced damages and reasonable attorneys’ fees.
PRAYER FOR RELIEF
Wherefore, RMDI prays for the following relief:
A. Judgment that Defendants have each infringed the ’900 Patent;
B. An order requiring Defendants to account for and pay to RMDI all damages
caused by their infringement of the ’900 Patent, whether lost profits or a reasonable royalty, and
to enhance such damages by three times in light of Defendants’ willful infringement, all in
accordance with 35 U.S.C. § 284;
C. Entry of a permanent injunction pursuant to 35 U.S.C. § 283 enjoining
Defendants, their officers, agents, servants, employees and those persons in active concert or
participation with them from further acts of patent infringement;
D. An order that RMDI be granted pre-judgment and post-judgment interest on the
damages caused to it by reason of Defendants’ patent infringement;
COMPLAINT FOR PATENT INFRINGEMENT Page -6-
E. A declaration by the Court that this an exceptional case and that RMDI be granted
its reasonable attorneys’ fees in accordance with 35 U.S.C. § 285;
F. An award of costs to RMDI; and
G. Any other relief that the Court may deem just and proper under the circumstances.
DEMAND FOR JURY TRIAL
RMDI demands trial by jury on all claims and issues so triable.
Dated: January 14, 2010. WORKMAN | NYDEGGER
By: /s/ James B. Belshe
James B. Belshe
Clinton E. Duke
Amber B. Leavitt
Attorneys for Plaintiff RMDI, LLC

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