Need Some Ideas To Raise Cash For Tenko Resubmition

A&S Conversions

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Much as I don't want to, I need to raise some cash for my resubmition of the Tenko 10-16 adapter. I need to raise about $10,000 to $12,000. I put four CF(W) tungsten bolts up for sale but, apparently I am asking too much for the new old stock bolts. Since I need the cash should I just list them at Fun Broker? I need two M10 lowers as I am submitting both an open and closed bolt versions, but must submit complete firearms to the ATF. I do have three lowers, but if I sold one, that would leave me dead in the water as far as continued testing. I am also planning to sell some clone roller delayed barreled receivers now that my HK sear is gone. Reasonable suggestions are welcome.

Scott
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Tobias Arms

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I am Seriously questioning the benefit of submitting stuff to the ATF for review.

Having seen how terrible the recent arguments of the ATF lawyers are, and how many 2A cases they have lost recently. I just do not see any opinion letter from them having any legal benefit anymore. The Judges in these cases are clearly not deferring to the ATF's judgment. Their judgment is being smacked down.

So what is the point of an ATF letter, if a judge will not defer to it and believe it without question? If it offers no definitive legal defence, what is the point?

PS once Chevron Deference is smacked down by the courts, that will be the final nail in the coffin for determination letter. As then the courts are not required to defer to the ATF's opinion as fact.

My suggestion is of course do not waste money that could be used for R&D on federal Bureaucrats.

PPS, of course i do not know the details of this Tenko that is mentioned. but we are all capable of determining if something is a machinegun or not, without the ATF's proven terrible legal advice. Oh, and they go back on what they say all the time too.
 

Jmacken37

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The problem is that permission was asked for already. I'd recommend selling transferrable MGs and making new Posties, assuming you have a manufacturing license.
 

Deerhurst

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I am Seriously questioning the benefit of submitting stuff to the ATF for review.

Having seen how terrible the recent arguments of the ATF lawyers are, and how many 2A cases they have lost recently. I just do not see any opinion letter from them having any legal benefit anymore. The Judges in these cases are clearly not deferring to the ATF's judgment. Their judgment is being smacked down.

So what is the point of an ATF letter, if a judge will not defer to it and believe it without question? If it offers no definitive legal defence, what is the point?

PS once Chevron Deference is smacked down by the courts, that will be the final nail in the coffin for determination letter. As then the courts are not required to defer to the ATF's opinion as fact.

My suggestion is of course do not waste money that could be used for R&D on federal Bureaucrats.

PPS, of course i do not know the details of this Tenko that is mentioned. but we are all capable of determining if something is a machinegun or not, without the ATF's proven terrible legal advice. Oh, and they go back on what they say all the time too.
I can appreciate what you are saying, especially since the aft has a pretty crappy record and is well known that determination letters mean almost nothing as they have and will go back on their word when it is convenient.


The Tenko has already been submitted and approved once then denied with only a material change and some BS reason about not actually testing the first submission but approving it anyways. It's already on the radar. Probably best to resubmit for him if nothing but to CYA.

I completely agree otherwise. There is no law that says you must submit for approval. Congress makes laws, law enforcement branches do not.
 

A&S Conversions

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For those that are not familiar with The Tenko 10-16, a little background. Ten years ago, I had the idea of making an "upper" that would use the mechanism of an AK in the receiver of a roller delayed. The following year I bought an M10 from Tom (VegasSMG). Instead of using a HK sear/trigger pack, why not use the M10 as the registered machinegun part? But the engineering and fabrication was beyond my abilities. In June of of 2017, I met up with an Engineer that could help me. We made a 3D printed version of the Tenko adapter, which allows the use of standard AR-15/16 uppers to be fired from a M10, that was custom fitted to my RPB double stamp receiver. In December we received a determination letter that the Tenko adapter was considered a firearm accessory.

In October 2018, we sent in a billet aluminum version and had three Beta testers put 10,000 rounds through three units. We found one small flaw and fixed it. In February 2019 we hear back from the ATF that they had changed their policy, they would ship back the adapter without determination, and we would need to resubmit as a complete firearm. I sent my original RPB M10 with one of the Beta units.

After six months (the original submission was 108 days), I tried contacting them as the confirmation letter they received the complete firearm said that I could expect the determination in six months. No response. Several RKIs suggested that we become a FFL holder, which we did. Still no response. I contacted a NFA specific lawyer and my senior Senator's office. I finally got a ATF response. They held the adapter in a vice bolted to a table, Used a C-clamp to hold a piece of angle iron to keep the recoil spring inside the adapter. They basically made the channel of a M10 and got it to fire. So the determination was that the aluminum adapter was a machinegun. The lawyer asked why the two different determinations for the same product only in a different material? The ATF said they didn't fire the plastic version because they were afraid to. The lawyer told me that he would need $100,000 retainer and two years for appeals. It would come down to whether the judge agreed with the ATF. He said that most judges would tend to go with the ATF determination. He said that our odds weren't good.

I am now 64. The money we will have in this is basically half of my net worth. Another manufacturer submitted their AR based upper a couple of months after we did. They got approval after two years and four months. I think we have a pretty good chance to get approval. Anything mechanical can be overcome, but our current design would be very hard to overcome. But that is up to the ATF. I don't have $100,000 dollars to fight them. I agree what they have done is BS, but I just don't have the resources to take them on in court.

I need to square up with my engineer and overnight ship and overnight return ship to M10s with two adapters and uppers. We will be submitting a closed bolt and an open bolt version. I need to come up with around $12,000 by the end of the year. I will sell whatever I need to to come up with the cash. This whole experience has really taken the fun out of shooting. So resubmit and patiently wait. Thank you all for your kind words and support. It means a lot.

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

root

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I normally sell assets when I need a little bit of loot like you mentioned for when I was self employed.

Problem right now is it's a buyers market unless it's real estate/land.

By assets I don't mean firearms.

Got old cars, high end collectables, gold silver, vacation property?
Those are all things that have stood the test of time against inflation.

And people are suffering from inflation pain on all fronts.
Why it's a buyers market people realize they can't live or eat the fancy car or umpteenth gun in the collection.

If you don't have the 10k in the bank or hard assets bought as investments it looks like you are down to 5 choices.

Firearms
2nd job
Loan
Investors
Selling the IP and all physical tenko items. ( if you can find a buyer at your asking price)
Letting the project go.

Pretty much in that order and none of them sound ideal for a maybe or what if.
And there are way more what ifs with the project as you have found out and posted about.
Not every biz venture works out.

I know it's not the advice you want or were looking for but it's all I got and it's coming from a guy that has owned some sort of self employed biz since I was 19

Wish you the best of luck I really mean that but it sounds like you are fighting a uphill battle to the top of Pikes Peak.

Here is to hoping it all works out and you find the funding needed in the least possible painless way.
 

mak91

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Scott, What about a crowdfunding project where you pre sell x number of receivers at deep discount with the understanding that the participants don't get anything until the device is approved.
And B.T.W. Scott as much as this has sucked for you you have at least done your due diligence to insure your device should be legal for the consumer to own when it comes to market. I for one would not spend a penny on something like this without it having gone through a determination process. Kudos to you and guys like Richard and Sam for following the process.
 

ericthered

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Im on the same page about the determination letter thing. The only benefit is that it might forestall future lawsuits with the aft.
That aside, you could do the preorder thing mentioned before, obviously there would be risk involved from the buyers perspective as you aren't in a position to guarantee things. All cool as long as everything is upfront. Could determine how many units you would need to pre sell to cover it at a discount.
You could also find a single or small group of investors. It would probably be beneficial to not make them business partners as thats where things can get messy if there is a flake involved.
Which i dont know what your situation looks like, or your plans. But your also going to need to manufacture these, which im guessing is just going to cost time and materials at this point (if you own your machine equipment or your friend is making them). So will still have to keep the lights on when manufacturing or paying for manufacturing.
Like mentioned, a small business loan might be your best bet as well. Whatever fits your situation best.
My only thought is that selling your guns to afford this may be a fine short term solution, but it will be a temporary solution. And you dont want to kill all of the fun in guns. You have made it quite a far way already, with working prototypes you are at the perfect time to do any of those suggestions. Even needing a little refinement and time for the feds to figure out how to ruin someones day, you got a proof of concept that was ready for production. So you are sitting at a pretty good point right now!
 

Grant435

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I would just start putting in serious overtime at work or get a side job and get REAL lean with the personal / home expenses. Didn’t you say once that you’re renting a place to run this business out of? I could be wrong but I thought that was pretty expensive if I remember correctly. Get out of that and find something more affordable if that’s the case. Have you done a RECENT poll to see how many buyers you would have? Im
Assuming the numbers still make sense but I’m sure you looked into that already. Sorry if I’m just stating obvious stuff. Lots of respect for what your doing
 

A&S Conversions

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Thank you all for your thoughts. We gave up the rental space a year and a half ago. I also gave up my 07/01. It was just too much overhead that I was not using. Even if I sold units at a big loss, let alone for my cost, I don't think that I could raise the $12,000.00 in a month. "Send us a grand and you might get something in a year or two" I just don't think would fly.

Maybe if we had a year or two to look for a SOT that would make a Post Sample M10 to help me continue testing, the other two other two receivers would be back by then. It would be so much easier to find a SOT with a Post Sample HK trigger frame than it would be to find a Post Sample M10. The M10 is not a popular Post Sample.

I got here chasing my dream. So I feel I am responsible to make that happen. This community doesn't have the resources, that say the HK sear community would have. But that is the whole reason I think the Tenko adapter will fly. Having the M10 lower have the basic functionality of a M16 RR, for half the cost, I would think would attract other than current owners of M10s. With pistol braces up in the air, maybe we won't have to wait two years plus for a determination. And maybe, just maybe, if I sit on my hands and patiently wait, we will get the determination that we need.

There was a member that offered to just sent me some funds to help. That moral support means the world to me. Thank you all so very much. Your support has helped us stay in the fight. I will start putting up some stuff on the auction site today. We will get the two samples to the ATF very soon. Thank you for your suggestions and support.

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

smdub

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This community doesn't have the resources, that say the HK sear community would have.
I think you aren't giving the community enough credit. I know lots of folks w/ a Mac... plus a dozen other machine guns. Don't assume just because you own a Mac that you are automatically one of the poors :) (HK joke there)

I too would like to help out. I want to support you. We *ALL* want to see you succeed. I think a kickstarter like campaign could work. You don't have to sell at a loss. Could be a deposit to be able to buy one at cost or something.

I really appreciate you keeping us up to date with all the details.
 

A&S Conversions

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I think you aren't giving the community enough credit. I know lots of folks w/ a Mac... plus a dozen other machine guns. Don't assume just because you own a Mac that you are automatically one of the poors :) (HK joke there)

I too would like to help out. I want to support you. We *ALL* want to see you succeed. I think a kickstarter like campaign could work. You don't have to sell at a loss. Could be a deposit to be able to buy one at cost or something.

I really appreciate you keeping us up to date with all the details.
I meant no offense. For that matter if the over 250 on the current Tenko list at Practical Solutions sent me $500, I'd have my target. Again I don't think that would be anything that I would ask, even if I offered double that off the purchase price. I think that the submissions would pass, but I would still need to pay the funds back if we don't get approved.

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

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You need 10 people @ $1200ea. 25 ppl @ $500 would do it. That is more doable than getting 250ppl on board.
Investing is a risk. Kickstarter does not guarantee a result to backers. Many people are ok with that. There have been some fairly famous failures (and scams.)
 

A&S Conversions

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ETA, Apparently the calculator in my head had a low battery. My math was incorrect. You are right, 25 investors at $500 each would do it. I certainly could double that investment with a $1,000 discount for the Tenko 10-16 (if approved) to those investors.

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

ETA, I am unfamiliar with crowd funding types of investments. I have always been a "do it on my own" kind of guy. I also need the money in about a month. My wife is at the end of her patience. She has lobbied very hard for me to walk away from the project. How many mechanical features is enough to garrantee approval?

We were in a very different position five years ago. We are still paying on the $50,000 to finish the engineering and manufacture of the Beta test units an initial run. Yes, I am very well aware that I should not have produced a product that did not have an approval letter for. Oh man, have I been put through the ringer for that. But at my core, I feel I am an optimistic. I was just changing the base material from nylon to aluminum, adding features that aloud for 95% of all registered M10s to be used, and finishing some features like making the pins mounting the upper to being captured.

The process of the redesign has been 10 times harder than the original design was to produce. Building a reliable robust product was a straightforward exercise. Adding mechanical features (complications to the mechanism) that would make firing the adapter, without the M10 lower receiver, more difficult without being too complicated for the end user. Obviously, the first submission was within the law. So how many additional features is enough? Thank you all for your moral support and encouragement. It means a lot to me. Thank you.

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