Below Summary of the issues covered in Attorney Glenn Bellamy’s 41P comments and exhibits:
- The Requirement of a local CLEO certification is not statutory in origin and exceeds the ATF’s statutory authority, making the proposed regulations vulnerable to attack.
- The regulatory requirement of a local CLEO certification imposes a discretionary third party approval that exceeds the statutory authority.
- The proposal fails to address many easily anticipated circumstances
- The Proposal fails to consider regulatory alternatives that would be more cost effective, serve legitimate statutory objectives, and avoid legal vulnerabilities.
- The proposed rules do not address how Form 1,4, and 5 entity applications pending at the time such a rule amendment is implemented would be affected.
This is another example of a well written comment for 41P. To read his comments and view his exhibits visit my 41p page at https://www.guntrustlawyer.com/41p.html
Glenn Bellamy is a Partner with more than two and a half decades of intellectual property litigation, patent and trademark prosecution, and U.S. Customs enforcement experience, first in Seattle and now in Cincinnati. He counsels clients on strategic plans for international Intellectual Property protection of everything from firearms and hydraulic machinery to toys and games. Glenn has litigated Intellectual Property cases throughout the country in federal courts and before the International Trade Commission. Glenn, his wife Renée, and two children live in Symmes Township, Ohio.