This may have already been posted, but just in case it has not, here is the superbly written letter from Q's attorney in response.
https://www.liveqordie.com/wp-conten...e-9-2-20-1.pdf
The Cliff notes:
1) The ATF action is a violation of due process by failing to provide adequate notice of how to conform one's conduct to the requirements of the law.
2) The ATF has failed to follow the requirements of the Administrative Procedure Act in making rules (in general, notice of rulemaking and an opportunity for comment before the rule takes effect, as well as other requirements set forth in the letter) under which pistol braces are to be evaluated.
3) The ATF is in violation of prior Supreme Court cases indicating that criminal statutes cannot be enforced when people have relied on past agency action and then the agency abruptly changes course.
4) If the Honey Badger is ultimately determined to be a short barrel rifle, refraining from applying the decision retroactively and providing guidance on a proposed solution will encourage customers to come forward to implement the solution without fear of prosecution, thus ensuring compliance.
I agree 100% with all of her points.