PSA: PlumCrazy Polymer Lowers ILLEGAL Says Letter from BATFE

    UPDATE APRIL 2016: PLEASE NOTE: The below article was written in 2014. CURRENT GENERATION PLUMCRAZY GEN II from E3 Arms and SUREFIRE INSTITUTE are fully compliant with BATFE.

    PlumCrazy was a brand of polymer AR-15 lower receivers that were manufactured by PCF Manufacturing until they mysteriously went out of business in late 2011. Recently, a company, whose name I have been asked not to disclose, sent in a sample of a PlumCrazy lower to the BATFE to find out if the method they used to attached the metal serial number plate to the polymer lower was legal. Turns out, its not! PlumCrazy lower receivers are illegal, and have always been illegal under Federal Law.

    Metal serial numbers plates attached to polymer firearms must be embedded in such a way that removing them will significantly damage or destroy the firearm. In the BATFE letter, dated June 18 2013, Firearms Technology Branch technicians were able to remove the PlumCrazy serial number using just a hammer and a screwdriver in just one minute and without doing any damage to the receiver. The letter says …

    During the examination of the submitted AR- 15 type firearm receiver section (serial number RM00501 ), FTB also found that both the height and depth of the serial number markings are acceptable and thus compliant with§ 478.92. With respect to the adequacy of the attachment of the insert for this frame, the FTB evaluation revealed that the serial number consisted of a thin sheet of metal-like material and was attached to the surface of the embedded metal insert. This serial number was easily removed when a hammer and screw driver were used to peel the sheet off of the metal insert. This action took approximately 1 minute and caused no damage to the receiver. (See enclosed photos depicting the removal of the serial number insert.)

    … the method used to attach the serial number insert (serial number RM00501) on the partial receiver sample is not compliant with Federal Law.


    A photo of the PlumCrazy lower from the BATFE Letter


    Signed Earl Griffith, Chief, Firearms Technology Branch

    The last thing posted on the PCF Manufacturing website, dated 6 October 2011, was this message (copied verbatim, including spelling errors and odd punctuation, emphasis added) …

    If you’re confused because you were looking for PlumCrazy Firearms,don’t be -·you’re in the right place; we are just adding a variance to our licence. Our composite lowers will carry the new branding and maintain the high level of quality you’ve come to expect from our products. We wil,l however, be phasing out the Plumcrazy branded lowers, so get them while you can! So what’s the reason for the branding change? Well, as we have more law enforcement and military wanting to use our products, having “PlumCrazy” on the side of the magwell may not be the best· idea……, that’s it -·no conspiracy or anything, just a simple business decision that allows us to further broaden our market place. What’s this change mean to you? Well, nothing unless you just can’t live without seeing “Plumcrazy” on your lower. We plan to maintain the same price point as before, and·continue to provide you with·the best customer service in the industry

    PumCrazy lowers were quite popular. There could be thousands of gun owners around the country who, in good faith, purchase an illegal product.

    UPDATE: Just to clarify, this letter is not online anywhere as far as I know. I do have the entire letter. The letter covers a number of unrelated questions a manufacturer asked the BATFE. Nothing else in it is newsworthy or interesting. I was asked not to publish the rest of the letter and so I will not.

    UPDATE: David Famiglietti and his company New Frontier Arms were not mentioned in the above post but David Famiglietti has been harassing us, making accusations and and throwing around insults (Apparently I am both Piers Morgan and also not a man).

    Phil was about to call David, when I decided it would be better to have his response on file, so I instead emailed David asking him a number of questions and asking him to provide proof that the PlumCrazy lowers and his own lowers were legal. 

    Hi David,

    You want to share you side of the story with me. I am not actually sure how you were involved with PCF. While it is obvious that PlumCrazy lowers and your New Frontier lowers were at some point based on the same mold, you will notice I never mentioned New Frontier in my blog post. You are welcome to share any information with me. If I believe it is necessary, I will set the record straight.

    I would ask that you also answer the following questions point by point. None of these are sensitive questions, but they provide context for this discussion.

    1) What happened to PCF? Why did it go out of business?

    2) How were you involved with PCF?

    3) Who owned PCF?

    4) Does New Frontier use the same or modified molds as PCF uses?

    5) Which company just lost a lawsuit against New Frontier? What was the lawsuit about?

    6) Are all PlumCrazy lowers illegally serialized, only some, or the only PlumCrazy lower serialized illegally as the one submitted to
    the BATFE last year?

    7) Can you provide me with a letter from the BATFE confirming that the PlumCrazy lowers are serialized legally?

    8) Can you provide me with a letter from the BATFE confirming that the New Frontier lowers are serialized legally?

    Regards, Steve Johnson

    Our conversation was of course on record. He had been on TFB discussing this issue, hurling insults, saying we got it all wrong and that he could not get in touch with me to discuss it. He could not then claim in the 4th email I received from him, and in reply to my reply, that we were having an off the record conversation.

    I want TFB readers to see his entire response in full so you can make up your own mind. David cannot accuse me AGAIN of taking things out of context.

    Steve, again, I wish you would just call like a man so we can discuss the
    issues, but if it’s easier to be behind a keyboard, I will re-type
    everything I had to comment on today for you here. I understand that you
    didn’t mention New Frontier Armory, but what you seem not to understand is
    myself and other dealers sold thousands of Plum Crazy lowers as well as tens
    of thousands of New Frontier polymer lowers and we are responsible to our
    customers for those products, so we had to answer all the silly questions we
    got today from concerned customers because of a one year old determination
    letter you posted. You realize that a determination letter is not a law,
    right? Or a regulation, right? It’s a onetime ruling/official stance on
    ONE SINGLE PIECE OF PRODUCT that was sent in, not an entire product line.
    You saying “ATF says Plum Crazy Polymer Lowers are ILLEGAL” is a blatant
    misinterpretation of the facts, and you should clearly see that. Again, a
    phone call would be much easier to clear up any confusion you have on this.
    An easy question to ask you is if ATF sent this reply almost a year ago, did
    they just decide to not enforce it or follow through with it after that? We
    get traces all the time on PCF lowers. We’ve gotten ATF inspections where
    agents have inventoried them along with thousands of other firearms on site.
    Why were they not confiscated?

    If you plan on using any of this e-mail in an article quoting me, I request
    a phone call first for permission so I can check with other parties involved
    in these matters that it may affect.

    I will try to answer your questions the best that I can, but because of
    pending legal matters and NDA’s that have been signed by myself, my
    customers, and my vendors, I hope you can understand why I can’t disclose
    some of the information requested.

    Again, a friendly phone call from you anytime on my personal cell will
    always be welcome and probably very helpful for both of us to better
    understand each other’s point of view.

    On to your questions:

    1) PCF had earned a bad reputation in the industry for their horrible
    customer service, and they were poor marketers. We were approached by an
    injection molding company as PCF was failing about possibly selling their
    products as well name branded for us, but they wouldn’t offer us an
    exclusive deal because they had an ongoing relationship with PCF, who they
    were also producing receivers on a variance for. We agreed to sell our
    almost identical product alongside PCF’s, and within 3 months we had sold
    more of our branded product than they had sold of their own PCF marked
    lowers over an almost 2 year period. No one was buying their product any
    longer because we offered the market an improved, more affordable, more
    reliable product, with better parts, and extremely better customer service
    and marketing to the public then they could offer. It got to a point where
    they had no need to order anymore product and eventually withered on the
    vine since they couldn’t compete. They also left the relationship with the
    injection molder owing a substantial debt for product delivered.

    2) I was not involved with PCF in any way besides being a dealer of their
    product up until we released our own branded polymer lower, the LW-15

    3) The original owners were Russ Maxwell and Ed Macinerney (2010 — with Ed later leaving the
    company on paper in 2012 (
    after Russ took on an investor by the name of Brian Baumkirchner who
    eventually bought all rights to PCF. There was much controversy over the
    investment and not being able to pay back the investment, and from what I’ve
    seen in legal documents that I had access to during litigation between
    Baumkirchner and NFA, Baumkirchner was lied to about what PCF actually owned
    (machines, molds, etc) and he came looking for his money from the molder and
    NFA when the PCF guys pointed fingers are way. This has since played out in
    court and is still an active court case where at this point, NFA has been
    dropped from any accusations in the suit after being proved innocent of all
    accusations, and the molder is in an ongoing leading preceding to recoup
    lost profits, legal fees, etc from Baumkirchner.

    Mcinerney later went on to start another similar company called E3 arms,
    that has also withered away:

    Baumkirchner (with Maxwell in the background) started yet another similar
    company which has also failed called U.S. Arms LLC which attempted to sell
    the “Patriot 15” polymer lower.

    As stated in your article with a funny jab at the spelling and grammatical
    errors on their website, they weren’t the best business man and could have
    done much better with the product they had access to if they understood
    public perception, customer service, and marketing. All of their ventures
    have gone to shit with the fault only being them, not their products.

    4) I can’t factually tell you that because I honestly don’t know as I have
    the receivers made for NFA on a variance with an AZ company. I can tell you
    that it is the same molder that was contracted by PCF, and the product is
    almost identical with some minor design changes, and material changes on
    several parts, including the receiver body itself to get more strength out
    of the product.

    5) The lawsuit details I am at liberty to share privately with you were
    discussed in #3. For obvious reasons I can’t go into more detail at this
    time because its an ongoing legal matter that involves friends and vendors
    of mine. I will try to dig up the complaint for you with a link that was
    made public about a year ago.
    6) That I am aware of, and understand after speaking with the actual MFG,
    there are NO illegally serialized Plum Crazy Firearm lowers that went out to
    customers. Like stated several times today, and where your main
    misunderstanding seems to be, is that I can send anything in with the New
    Frontier name, or any company name to ATF for a determination. That does
    not in any way mean that I will or should produce it that way in mass
    production for distribution. It certainly would not be produced in that way
    after ATF determines there is an issue with it. This has happened with
    other products, and ATF simply asks the mfg to make changes to said products
    to comply and everyone moves on with life. So no, according to ATF and the
    actual mfg of the lower receivers, the lowers that made it to market are not
    in any way illegal or in violation of any ATF regulation. If they were
    action would have been taken on several occasions over the past year since
    that determination letter was issued. I have good knowledge of the serial
    number ranges produced as PCF and NFA, and I know the lower in that picture
    was an initial demo lower produced for PCF, so I know one of the 3 mentioned
    above (or one of their associates) sent that in after modifying it. I am
    assuming it was E3 Arms and associates, since one of the captions on a
    picture you posted in your article quoted “E3 Arms”.
    7) No I can’t because I don’t possess that information since I am not / was
    not the actual mfg of PCF lowers. I can however tell you from my experience
    selling them, and later taking on a similar product line that the serial
    number is on ONE piece of metal square tubing that is molded into the
    receiver, very similar to Glock’s process, and meets all guidelines and
    regulations posted by BATFE. Remember, just because you saw a letter that
    says ONE sample that was sent in was not in compliance in NO WAY means all
    produced were not. I read in the letter (or the small part of the letter
    you revealed) That the serial number was on a second piece of “metal like
    material” that could be peeled off. This is not the case on any PCF that I
    sold as they all have box steel embedded with numbers engraved in them as
    stated a few lines above. That leads me to believe it was modified before
    sent to ATF to use as a “wild card” in ongoing legal battles with the
    company involved.

    8) Same story as #7. ATF has inspected the actual mfg as well as our
    facilities and have assured us both that in no way are we having any
    compliance or mfg issues. We ask every time a rumor like this pops on the
    net and get the same answer: “If there was something we wanted change or
    didn’t like, you’d hear it from us first, not a blog on the internet” (the
    answer I got this morning from a local agent) and “If it wasn’t legal, do
    you think we would let you keep making/selling them?” (the answer from an AZ
    agent when the molder called them this morning)

    Again, I hope you can see there is more to the story than you know, and I’m
    not just some joker on the internet talking shit for no reason from Mom’s
    basement. I hope there are no hard feelings, but hopefully even slightly
    see where I’m coming from, and how this article could have startled some
    already “scared of the gov” customers and vendors into a frenzy by not
    understanding the whole situation. The upsetting part was the misleading
    title and the article were based purely off the speculation that all lowers
    were produced the same way to the one that was sent in to ATF for
    determination. ATF made it clear in their response for a reason, so it
    wouldn’t be misinterpurted. They clearly state that that ONE single part /
    serial number is not in compliance. In no way has or will the ATF make a
    statement saying that all PCF lowers are illegal (which is what your title
    states vividly and in CAPS to emphasize “ILLEGAL”).
    No hard feelings, and I’d love to hear back from you, especially a quick
    phone call as time permits. Besides this article I enjoy following your
    site, and have promoted links to articles on many occasions and will
    continue to do so in the future. I hope we can move past this as industry
    partners, if not friends.
    Let me know if there’s anything else I can help explain!


    I am disappointed David could not provide any documents supporting his argument.

    This ends the matter for TFB. Both sides have made their argument. Now you have Dave’s side of the story and you can make up your own mind.

    Steve Johnson

    I founded TFB in 2007 and over 10 years worked tirelessly, with the help of my team, to build it up into the largest gun blog online. I retired as Editor in Chief in 2017. During my decade at TFB I was fortunate to work with the most amazing talented writers and genuinely good people!