0 0 t
1 DENNIS J. HERRERA, State Bar#l39669 City Attorney ,, 2 YVONNE R. MERE, StateBar#I73594 Chief of Complex and Affirmative Litigation 3 VICTORIA L. WEATHERFORD, State Bar #267499 AILEEN M. MCGRATH, State Bar #280846 4 Deputy City Attorneys 1390 Market Street, 6th Fl. 5 San Francisco, California 94102-5408 ~~~ Telephone: (415) 554-4236 FEB 0 9 2017 6 Facsimile: (415) 554-3985 E-Mail: victoria. weatherford@sfgov .org CLERK OF THE COURT 7 E-Mail: [email protected] BY: - ROS§ALY DELAVEGA Deputy Clerk 8 Attorneys for Plaintiff 9 THEPEOPLEOFTHESTATEOFCALIFORNIA Ex rel. San Francisco City Attorney Dennis J. Herrera IO
11 SUPERIORCOURTOFTHESTATEOFCALIFORNIA 12 COUNTY OF SAN FRANCISCO 13 UNLIMITED JURISDICTION 14
15 THE PEOPLE OF THE STATE OF Case No. CALIFORNIA, ex rel. San Francisco City 16 Attorney Dennis J. Herrera, COMPLAINT FOR INJUNCTIVE RELIEF AND CIVIL PENALTIES FOR VIOLATIONS 17 Plaintiff, OF.BUSINESS AND PROFESSIONS CODE SECTION 17200 18 vs.
19 BADGER MOUNTAIN SUPPLY, an unincorporated business; 7.62 PRECISION, an 20 Alaska corporation; SHOOTERS PLUS, an unincorporated business; L.A.K. 21 ENTERPRISES, d/b/a/LAKSUPPLY, a Wyoming limited liability company; MARK 22 THOMAS KUBES, d/b/a BUYMILSURP.COM; and DOES I through 23 50, inclusive.
24 Defendants.
25
26
27
28
PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\01168095.doc 0 0
1 Plaintiff, the People of the State of California, acting by and through San Francisco City
2 Attorney Dennis Herrera, is informed and believes and alleges as follows:
3 INTRODUCTION 4 I. Gun violence and trafficking in illegal fuearms are critical issues plaguing California 5 communities. In 2015, 1,276 homicides were committed with a fuearm in California. The same year
6 in San Francisco, 34 homicides were committed with a firearm; there were an additional 122 non-fatal
7 shootings; and the Saµ Francisco Police Department seized 1,085 illegal fuearms.
8 2. Gun violence involving large-capacity fuearm magazines poses especially substantial 9 dangers to public safety. Large-capacity fuearm magazines are detachable ammunition boxes or
1O drums that contain more than 10 rounds of ammunition and feed that ammunition into an automatic or
11 semiautomatic firearm, whether a handgun or a long gun. A semiautomatic fuearm fires one bullet for
12 each pull of the trigger and then automatically loads the next round in preparation for the next shot.
13 3. Large-capacity magazines multiply guns' destructive power by allowing a shooter to 14 fue many rounds.without stopping to reload. These oversized magazines can store more than 100
15 rounds of ammunition and significantly increase a shooter's ability to injure and kill large numbers of
16 people quickly.
17 4. Large-capacity magazines have been used in many recent, high-profile mass shootings, 18 such as the 2016 Orlando night club shooting, which killed 49 people; the 2015 San Bernardino attack,
19 which killed 14 people; the 2015 Charleston church shooting, which killed nine people; the.2012
20 Aurora, Colorado shooting, which killed 12 people; the 2012 Newtown, Connecticut shooting, where
21 20 children at Sandy Hook Elementary School were killed alongside several of their teachers; the 2011
22 Tucson shooting, which killed 6 people and injured f3 people, including a member of the United
23 States House of Representatives; the 2009 Fort Hood, Texas shooting, which killed 13 people and
24 injured 34 people; and the 2007 Virginia Tech shooting, which killed 32 people.
25 5 . . Large-capacity magazines have also been used against San Francisco police officers, 26 including a 2013 incident at India Basin Shoreline Park, where undercover police officers were
27 targeted with semiautomatic pistols containing 30-round magazines.
28 6. An analysis of mass shootings between 2009 and 2015 found that shootings involving 1 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirm\li2017\170149\01168095.doc 0 0 .. 1 large-capacity magazines-or assault weapons that were likely equipped with such magazines-were
2 more dangerous and more deadly, with approximately 155 percent more people injured and 47 percent
3 more victims killed than in mass shootings without large-capacity magazines. (See Everytown for
4 Gun Safety, Analysis of Mass Shootings (Aug. 31, 2016),
5
6 country's leading experts on gun violence has reported that the size of the magazine used in a shooting
7 is "associated with the amount of damage a weapon '?an cause." (Alex Yablon, Bans on High-
8 Capacity Magazines, Not Assault Rifles, Most Likely to Limit Mass Shooting Carnage (June 13,
9 2016),
1O 2017].) Thus, preventing access to large-capacity magazines is a critical means of protecting the
11 public from mass shooting violence. (Ibid.)
12 7. Because large-capacity magazines are so lethal, the State of California enacted a 13 prohibition on the sale, manufacture, or import of large-capacity magazines in 1999, and further
14 declared those devices to be public nuisances. (Pen. Code,§ 32310 et seq.) The law did not prohib~t
15 the continued possession of large-capacity magazines by people who owned them before the
16 sale/manufacture/import prohibition took effect on January 1, 2000. Nor did the law prohibit these
17 grandfathered owners of pre-ban large-capacity magazines from repairing and maintaining their
18 magazines by taking them to licensed de~lers and gunsmiths. The law prohibits these grandfathered
19 owners, and all other residents of the state who are not law enforcement officers or otherwise exempt,
20 from acquiring new large-capacity magazines. 1
21 8. Instead of complying with the law, companies skirted the statewide ban on large- 22 capacity magazines by selling so-called large-capacity magazine "repair kits" or "rebuild kits" to
23 California consumers. These kits are not individual magazine parts to replace, say, a worn-out spring
24 or a cracked baseplate in a lawfully possessed magazine. Rather, they are· the complete parts of
25 26 1 InNovember2016, California voters passed Proposition 63, which will generally prohibit possession oflarge-capacity magazines after July 1, 2017. (See Pen.I Code,§ 32310, subds. (c), (d).) 27 Proposition 63 requires individuals who own large-capacity magazines to dispose of them prior to July 1, 2017 by selling them to a licensed firearms dealer, transferring them to law enforcement, or 28 removing them from the state. (Ibid.) · 2 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirm\li2017\170149\01168095.doc 0 0
1 disassembled large-capacity magazines packaged under the guise of a "kit." Purchasers can readily
2 assemble the parts into brand-new, fully functional large-capacity magazines. In 2013, the California
3 Legislature strengthened the existing law by making it a misdemeanor to knowingly manufacture,
4 import, keep for sale, offer, or expose for sale, or give, lend, buy, or receive any large-capacity
5 magazine conversion kit that is capable of converting an ammunition feeding device into a large-
6 capacity magazine.2 (Pen. Code,§ 32311.)
7 9. The City and County of San Francisco (the "City") took further action to protect its
8 residents from gun violence by enacting a ban on the possession of large-capacity magazines
9 beginning in April 2014, with some limited exceptions. (S.F. Police Code,§ 619.) The City's Police
10 Code prohibits the possession of large-capacity mag?Zines whether assembled or disassembled,
11 meaning that the possession of a large-capacity magazine conversio~ kit, which consists of all of the
12 parts of large-capacity magazine disassembled in the disguise of a repair kit, violates the City
13 ordinance.
14 10. D~spite California's ban on such kits, Defendants Badger Mountain Supply, 7.62
15 Precision, Shooters Plus, LAK Supply, and Buymilsurp.com (collectively, "Defendants") continue to
16 offer for sale and, on information and belief, sell disassembled large-capacity magazine kits to
17 consumers in California. Indeed, these Defendants target sales directly to California residents.
18 Further, :Defendants mislead California buyers.to believe that these "repair kits" are legal
19 notwithstanding state law to the contrary.
20 11. Defendants are violating California's ban on large-capacity magazines by marketing, 21° offering, and, on information and belief, selling large-capacity magazines, in the guise of "repair kits"
22 or "rebuild kits," to customers in California. They are also directly violating California's ban on these
23 kits, and are aiding and abetting the illegal purchase, importation, and manufacture of these kits by
24 California consumers. Defendants are, or should be, aware that customers will be violating California
25 law by purchasing, importing, and assembling large-capacity magazine repair kits. Defendants are
26 thus flouting a law that is intended to protect the safety of California residents by stopping the sale of
27 2 This law is subject to the same limited exceptions that apply to large-capacity magazines 28 themselves: 3 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\0l 168095.doc 0 0
1 these products in California. By their unlawful and unfair conduct, Defendants profit at the expense of
2 public safety throughout the State of California.
3 12. By marketing, offering, and, on information and belief, selling disassembled high-
4 capacity magazines to San Francisco residents, the Defendants are also aiding and abetting the illegal
5 possession of disassembled large-capacity magazines by San Francisco consumers. Defendants are or
6 should be fully·aware that customers will be violating San Francisco law by possessing a disassembled
7 large-capacity magazine. Indeed, Defendants' advertising representations show that they understand
8 these kits to be functionally equivalent to large-capacity magazines. For instance, Defendant
9 Buymilsurp.com advertises that the parts in the kit are sufficient to build a full large-capacity
10 magazine. In addition, Defendant LAK Supply markets its "mag parts kit" as the functional equivalent
11 of a "hi cap magazine." Defendants are thus flouting a law that is intended to protect the safety of San
12 Francisco residents by eliminating these products entirely from within the City's borders. By their
13 unlawful and unfair conduct, Defendants profit at the expense of public safety throughout the City_and
14 County of San Francisco.
15 13. These are unlawful, unfair, and/or fraudulent business practices that compromise San
16 Francisco and: California's public safety objectives, make a mockery of state and local law, and
17 knowingly or intentionally aid and abet the ~nlawful possession, importation, and/or manufacture of
18 large-capacity magazines by California residents. This Court should enter a preliminary and
19 permanent injunction to stop these practices and should order the Defendants to pay civil penalties for
20 their past acts of unfair competition.
21 PARTIES
22 14. Plaintiff the People of the State of California, by and through San Francisco City
23 Attorney Dennis J. Herrera ("People"), prosecutes this action pursuant to Business and Professions
24 Code section 17200.
25 15. Defendant Badger Mountain Supply, Inc. ("Badger Mountain Supply") is an
26 unincorporated business with an office and warehouse located in the State ofWashington. Badger
27 Mountain Supply represents that it is "based in and shipping from Washington and California,"
28 (Badger Mountain webpage,
1 2017].) Badger Mountain Supply offers and markets large-capacity magazines to customers in San
2 Francisco and California. Badger Mountain's internet site advertising for sale large-capacity magazine
3 "repair kits" is accessible in San Francisco and, on inf~rmation and belief, Badger Mountain Supply
4 has sold or intends to sell its repair kits to customers in San Francisco and California.
5 16. Defendant Shooters Plus is an unincorporated online business located in the State of 6 Mississippi. Shooters Plus sells guns, rifles, shooting accessories, and gun parts. Shooters Plus offers
7 and markets large-capacity magazines to customers in San Francisco and California. Shooters Plus' s
8 internet site advertising for sale firearm "rebuild kits" is accessible in San Francisco and, on
9 information and belief, Shooters Plus has sold or intends to sell those "rebuild kits" to customers in
10 San Francisco and California.
11 17. Defendant L.A.K. Enterprises, LLC, d/b/a LAK Supply ("LAK Supply") is a limited
12 liability company located in the State of Wyoming. LAK Supply offers and markets large-capacity
13 magazines to customers in San Francisco and California. LAK Supply operates a website that offers
14 "a variety of firearm-related products, specializing in magazines and mag repair kits for those of you
15 in anti-2A territory." (LAK Supply webpage,
16 Supply's internet site advertising for sale "mag repair kits" is accessible in San Francisco and, on
17 information and belief, LAK Supply has sold or intends to sell those "mag repair kits" to customers in
18 San Francisco and California.
19 18. Defendant 7.62 Precision is a corporation located in the State of Alaska. 7.62 Precision
20 offers and markets large-capacity magazines to customers in San Francisco and California. 7 .62
21 Precision .operates a website that is accessible in San Francisco and that advertises for sale firearms
22 accessories and magazines, including high-capacity magazine repair kits. On information and belief,
23 7 .62 Precision has sold, or intends to sell, illegal high-capacity magazine repair kits to customers in
24 San Francisco and California.
25 19. Defendant Mark Thomas Kubes d/b/a Buymilsurp ~ com ("Buymilsurp.com") offers and
26 markets large-capacity magazines to customers in San Francisco and California. Buymilsurp.com is a
27 website that is accessible in San Francisco and that advertises for sale what it describes as "military
28 surplus" items, including firearms, magazines, and other forms of ammunition. (Buymilsurp.com 5 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\01 !68095.doc 0 0
1 webpage,
2 information and belief, Buymilsurp.com has sold or intends to sell high-capacity magazine repair kits
3 to customers in San Francisco and California.
4 20. Plaintiff the People is not aware of the true names and capacities of Defendants sued 5 herein as DOES 1 through 50, inclusive, and therefore sues these Defendants by such fictitious names.
6 Each fictitiously named Defendant is responsible in some manner for the violations of law alleged.
7 The People will seek leave of court to amend this complaint to allege their true names and capacities
8 when that information is ascertained. Whenever reference is made in this Complaint to "Defendants,"
9 such reference shall include DOES 1 through 50 as well as the named Defendants.
10 JURISDICTION AND VENUE
11 21. The Superior Court has jurisdiction over this action. The Defendants are conducting 12 unfair, unlawful, and/or fraudulent business practices in California, and the City Attorney has the right
13 and authority to prosecute these cases on behalf of the People.
14 22. Venue is proper in this Court because some of the injuries of which the People 15 compiain have occurred in San Francisco and because injunctive relief is necessary to stop all of the
16 Defendants, and each of them, from delivering large-capacity magazine "repair kits" to San Francisco
17 or marketing and selling them to San Francisco residents.
18 DEFENDANTS ILLEGALLY MARKET AND, ON INFORMATION AND BELIEF, SELL IDGH-CAPACITY MAGAZINE REPAIR KITS TO RESIDENTS IN SAN FRANCISCO AND 19 CALIFO~ .
20 23. With few exceptions, California Penal Code section 32311 prohibits any person in . . 21 California, after January l, 2014, from knowingly manufacturing, importing into California, keeping
22 for sale, offering, or exposing for sale, or giving, lending, buying, or receiving any large-capacity
23 magazine conversion kit. These conversion, or repair, kits are capable of converting an ammunition-.
24 feeding device into a large-capacity magazine. The statute defines a large-capacity magazine
25 conversion kit as ·"a device or combination of parts of a fully functioning large-capacity magazine,
26 including, but not limited to, the body, spring, follower, and floor plate or end plate, capable of
27
28 6 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\01168095.doc 0 0
1 converting an ammunition feeding device into a large-capacity magazine." (Pen. Code,§ 32311.)3
2 24. Section 619 of the San Francisco Police Code prohibits any person, corporation, or 3 other entity in San Francisco from possessing a magazine, whether assembled or disassembled, with
4 the capacity to accept more than ten rounds, effective beginning in April 2014. A violation of this
5 ordinance is a crime, and is punishable as a misdemeanor offense. The Code provides for very narrow
6 exceptions such as gunsmiths and government officers authorized, to possess large-capacity magazines
7 {or their work.
8 25. These laws grew out of Cali~ornia Penal Code sections 32310 et seq., which has been in
9 effect since January 1, 2000 and prohibits any person in California from manufacturing, importing,
10 selling, giving, or lending any large-capacity magazine. That prohibition on importing or selling
11 large-capacity magazines has no exception for importing additional large-capacity magazines to
12 cannibalize for parts. The Legislature and the San Francisco Board of Supervisors adopted the more
13 recent restrictions on repair kits and disassembled high-capacity magazines to prevent sellers of high-
14 capacity magazines from attempting to flout this law.
15 26. Notwithstanding these clear prohibitions, each of the Defendants is marketing and, on
16 information and belief, selling disassembled large-capacity magazines to California and San Francisco
17 consumers under the guise that these "repair kits" are lawful. Thus, these Defendarits are violating
18 California Penal Code section 32311 on its face by offering for sale and, on information and belief,
19 selling these repair kits to California residents. Defendants are further violating California Penal Code
20 section 32310 by offering and, on information and belief, selling disassembled high-capacity
21 magazines to California residents. Through this same conduct, Defendants are also aiding and
22 abetting the violation of this law by California residents who purchase, import into the State, and then
23 assemble these kits. In addition, the Defendants are aiding and abetting the violation of the San
24 Francisco Police Code Section 619 by individuals who purchase and then possess such kits in the city.
25 Furthermore, by offering large-capacity magazine "repair kits" for sale on their websites, each of the
26 3 Until Proposition 63 goes into effect on July 1, 2017, a limited subset of persons are exempt 27 from the manufacture/sale/importation ban, including law enforcement and military personnel and dealers licensed to sell high-capacity magazines to them, as well as persons who possessed a high- 28 capacity magazine before the January 2000 ban was enacted. 7 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\01168095.doc 0 0
1 Defendants also falsely represents that California and San Francisco consumers may lawfully purchase
2 disassembled large-capacity magazines as "repair kits."
3 27. Defendants know or should know that their customers are unlikely to satisfy the limited
4 exceptions under state and city law that would permit them to purchase or possess large-capacity
5 magazines or repair kits. Defendants know or should know that their customers are instead unlawfully
6 purchasing, importing, and/or possessing these pro~ucts from the Defendants. None of the Defendants
7 · conditions its sale of "repair kits" to California customers on a customer's assurance that he or she
8 may purchase such "repair kits" because he or she meets one of the limited exceptions in the
9 California or San Francisco laws.
10 Badger Mountain Supply
11 28. Specifically, Badger Mountain Supply has violated California Penal Code sections
12 32310 and 32311 and aids apd abets the violation of both California Penal Code section 32311 and
13 San Francisco Police Code Section 619. Badger Mountain Supply illegally markets and, on
14 information and belief, sells repair kits into California and San Francisco. Badger Mountain Supply's
15 internet site advertising these wares is accessible in San Francisco and California. In fact, Badger
16 Mountain Supply's internet advertisements marketing high-capacity magazine "rebuild kids"
17 specifically target California customers by advertising that "[t]o comply with recent California laws
18 regarding magazine rebuild kits, customers buying rebuild kits to be shipped to California will receive
19 two shipments: the contents of each shipment not containing sufficient parts to assemble a functional
20 magazine. Additional shipping charges may apply to CA customers due to additional packaging and
21 shipping."
22 Ill
23 Ill
24 II I
25 Ill 26 Ill
27 Ill
28 Ill 8 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\0l 168095.doc 0 0
1 Screenshot of Badger Mountain Supply's website advertising "Rebuild Kits"
2 REB UILD KI T DET AILS 3
4 A rebuild I repair kit is a new magazine that has been opened disassembled a d packaged.for shipping Rebuild Kits may be sed to repair ex1sbng magazines or assembled and used m a•cordance to local laws and restnc!lons 5 t CA LI FOR NIA BU YERS ! 6
7 To comply with recent Cal1fom1a laws regarding magazine rebuild lots, customers buying rebuild lots to be shipped to Cahfomla will receive two shipments the contents of each 8 sh>pment not containing sufficient parts to assemble a fully funcbonal magazine Add1bonal shipping charges may apply to CA customers due to addibonal packaging and shipping 9 Rebw'd krts are not returnable 10
11
12
13
14 . A!o.1END2 30 RD AR15iM4 MAGAZINE 5 56 X 45 . AMEND2 30 RD AR 15J ~4 MAGAZINE 5 56 X 45 - TAN BUY-2-GET-1-FREE MAGPUL PMAG MOE 5 56 30RD BLACK (Rebuild Kit) {Rebu:'d Kit) BLK (Rebuild Kit) 15 Amend2 Amend2 Magpul lndustnes $15 . 95 ~ $1595 ~ $4695 ~ 16
17
18
19 ETS MAG FOR GLK 9MM 15RD SMOKE (Reburld Krt) ETS MAG FOR GLK 9MM 17RD SMOKE (Rebuild Kit) ETS lo.IAG FOR GLK 9MM 31RD SMOKE (RebUJ 'd Kit) 20 Elrt e Tac.bcal Systems Elite Tacl!cal Systems Elite Tacbcal Systems $32.95 $32.95 $36.95 21
22
23
24 KRISS MAGEX ASSEMBLED 25RD GKL21 t.1AG LANCER 5AWM 223REM 2iiRD TRANS CLEAR LANCER L5AWM 223REM 30RD TRANS CLEAR 25 (Rebuild Kit) (Rebu1'd Kit) (Rebuild KJ!) KRISS Lancer 26 l ancer $69.95 $33.95 $33.95 27 28 9 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affinn\li2017\170149\0l 168095.doc 0 0
1 29. Badger Mountain Supply falsely represents the legality of these repair kits to California
2 and San Francisco customers. As described in paragraph 28, Badger Mountain Supply's website
3 expressly invites California consumers to purchase repair kits that will be shipped in two separate
4 boxes. Badger Mountain Supply falsely represents to its customers that packaging high-capacity
5 magazine repair kits in this way enables its customers to legally import these products into the state.
6 But neither state nor San Francisco law provides an exception for repair kits shipped in this manner,
7 and the product Badger Mountain Supply advertises and sells remains illegal under those laws.
8 Shooters Plus
9 30. Shooters Plus has violated California Penal Code sections 32310 and 32311 and aids 10 and abets the violation of both California Penal Code section 32311 and San Francisco Police Code
11 Section 619. Shooters Plus illegally markets and, on information and belief, sells repair kits into
12 California and San Francisco. Shooters Pius's internet site advertising these wares is accessible in San
13 Francisco, and Shooters Plus has, on information and belief, sold or intends to sell its "rebuild kits" to
14 San Francisco customers. On its website, Shooters Plus explicitly targets the sale of large-capacity
15 magazine rebuild kits to states, such as California, where large-capacity magazines are banned. On its
16 internet page listing the types of magazines for sale, Shooters Plus directs customers to click on a link
17 "for info on converting High Capacity Magazines to Rebuild Kits for ban States such as California,
18 Colorado, Connecticut, Hawaii, Maryland, Massachusetts, New Jersey, New York, and Chicago, IL."
19 See Exhibit A hereto (Shooters Plus webpage,
20 30, 2.017].) To buy a rebuild kit, Shooters Plus instructs consumers to "simply click on the magazinels
21 you need, then click on the checkbox under each magazine that reads 'Convert to Rebuild Kit.'" For
22 example, a customer can purchase a 30-round magazine and convert it to a rebuild kit for $2.00.
23 111
24 II I 25 Ill 26 Ill 27 Ill 28 Ill 10 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirm\li2017\170149\0l 168095.doc 0 0
1 Screenshot of Shooters Plus website offering ''Magazine Rebuild Kit"
2 Magpul PMAG Magazine M2 MOE 30 Round AR·15 I M1~ ·Block . 3 4
5
6
7
8 Price: $13.95 Items Remaining: 30 9 Item# MAG571 BLK Magpul PW.G Magazine with Magpul Anti-Tilt FOiiower Black, 30 Round. AR-151M16 , .223 15.56 10
The Magpul PMAG {Polymer MAGazine) is a lightNeight 5.56 NATO M-16 compatible magazine. PMAG utillZes a resilient stainless steel sprjng for corrosion 11 resistance. Gen M2- 12 • Constant-cuive internal geometry for smooth feeding • Magpul anti-tilt, self lubricating follower for increased reliabil ity • Stainless steel spring for corrosion resistance 13 • Fits AR15, M4, M16 chambered in .223 and/or 5 56 • Tex1ured gripping surface • 30 round 14 • Black • oust cover not Included 15 This option only applies to customers in CA. CT, HI, NY, NJ, MA, MD and CO: 0 Magazine Rebuild Kit (add $2.00) Quantity: 16 c=J 17
18 31. Shooters Plus falsely represents the legality of these repair kits to California and San
19 Francisco customers. As shown in paragraph 30, the company's website informs customers that while
20 it is '.'unlawful" for the company to "ship complete standard capacity magazines" to "ban states ... it
21 is legal for us to ship these magazines in the form of rebuild kits as long as the customer is using the
22 rebuild kit to rebuild I repair magazines that he or she legally owned before the Assault Weapon Ban.
23 Our rebuild kits will be shipped unassembled and there is currently a $2.00 fee for each rebuild kit."
24 Shooters Plus thereby falsely suggests to California consumers that they may lawfully purchase these
25 "rebuild kits."
26 Ill
27 Ill 28 11 I 11 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affmn\li2017\l 70149\01168095.doc 0
1 LAKSupply
2 32. LAK Supply has violated California Penal Code sections 32310 and 32311 and aids and
3 abets the violation of both California Penal Code section 32311 and San Francisco Police Code
4 Section 619. LAK Supply illegally markets and, on information and belief, sells repair kits into
5 California and San Francisco. LAK Supply's website states that "All hi cap magazine orders from ban
6 states will automatically be converted into complaint mag parts kits when you place your order." See
7 Exhibit B hereto (LAK Supply Webpage,
8 2017].) LAK Supply's internet site advertising these wares is accessible in San Francisco, and LAK
9 Supply has sold or intends to sell its "mag parts kits" to San Francisco customers.
10 33. Additionally, LAK Supply falsely represents the ·legality of these repair kits to
11 California and San Francisco customers. By suggesting that the company takes special action to
12 convert "hi cap mag orders" into "mag part kits" when customers in "ban states" order high-capacity
13 magazines, LAK Supply falsely represents that customers in "ban states" may legally purch'1Se the
14 product when it is disassembled into its component parts.
15 7.62 Precision
16 34. 7 .62 Precision has violated California Penal Code sections 32310 and 32311 and aids
17 and abets the violation of both California Penal Code section 32311 and San Francisco Police Code
18 Section 619. 7.62 Precision illegally markets and, on information and belief, sells repair kits into
19 California and San Francisco. 7 .62 Precision targets the sale of such illegal conversion kits to
20 California residents and makes it clear that such kits are nothing more than disassembled high-capacity
21 magazines. 7.62 Precision calls its rebuild kit a "California Magazine Rebuild Kit" (emphasis added.)
22 In addition, its website states that "[t]hese parts kits are intended for California customers only. Any
23 orders for these magazines from locations other than California will be voided." See Exhibit C hereto
24 (7.62 Precision webpage,
25 1, 2017].)
26 35. 7.62 Precision falsely represents the legality of these repair kits to California and San
27 Francisco customers. By suggesting that the rebuild kit is specially made for California customers, .
28 7.62 Precision falsely represents that it is legal for California purchaser to acquire the kit. 12 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affum\li2017\170149\0l 168095.doc 0 0
1 Buymilsurp.com
2 36. Buymilsurp.com has violated California Penal Code sections 32310 and 32311 and aids - . 3 and abets the violation of both California Penal Code section 32311 and San Francisco Police Code
4 Section 619. Buymilsurp.com illegally markets and, on information and belief, sells repair kits into
5 C~lifornia and San Francisco. Buymilsurp.com's advertisements show that the company is fully aware
6 that its "repair kit" is simply a high-capacity magazine in disguise. For example, the company
7 advertises a 30-round magazine rebuild kit, showing a picture of a full magazine but stating that ~t is in
8 fact selling '"Disassembled' Spare Parts Kits" that are not as pictured but sent as "5 individual parts."
·9 Screenshot of Buymilsurp.com ''Rebuild Kit" 10
11
12
13
14
15
16 .17
18
19
20
21
22 Similarly, the company sells another 30-round magazine, stating that it is a "completely
23 disassembled magazine for Spare Parts."
24 II I
25 Ill
26 Ill
27 Ill 28 Ill 13 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirrn\li2017\170149\01168095.doc 0 0
Screenshot qf Buymilsurp.com ''Rebuild Kit" 1 2
3
4 5
6
7
8
9
10
11 37. Buymilsurp.com falsely represents the legality of these repair kits to California
12 and San Francisco customers. For example, as shown in paragraph 36, the company's website
13 explicitly-and falsely-states that an illegal repair kit is "OK TO SHIP TO CA." See Exhibit D
14 hereto (Buymilsurp.com webpage, 15 rebuild-kit-762x39-tapco-black-p-42852.html>,[as of Feb. 1, 2017].) Similarly, as shown in paragraph 16 36, on a webpage selling another "disassembled" 30-round magazine.the company states that it ''Can 17 Ship to CA"-even though it is illegal to sell the product-to customers in the state or for customers to. 18 buy the product in the ~tate. 19 CAUSE OF ACTION FOR VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTION 17200 AGAINST ALL DEFENDANTS 20 21 38. The People incorporate by reference paragraphs 1 through 37 inclusive. 22 39. California Business and Professions Code section 17200 prohibits any "unlawful, unfair 23 or fraudulent business act or practices." Each of the Defendants has engaged in unlawful, unfair 24 and/or fraudulent business acts and practices in violation of section 17200, including but not limited to 25 as .follows: 26 a. Each of the Defendants has violated Californi~ Penal Code section 32310 by 27 offering into California and exposing for sale disassembled large-capacity magazines; 28 /// 14 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affmn\li2017\170149\01168095.doc 0 0 1 b. In addition, each of the Defendants has violated California Penal Code section 2 32311 by offering into California and exposing for sale large-capacity magazine conversion 3 kits; 4 c. Each of the Defendants, with knowledge or constructive knowledge, has also 5 aided and abetted violations of California Penal Code section 32311 's ban on buying repair kits 6 by marketing and selling large-capacity magazine conversion kits to individuals in California; 7 d. Each of the Defendants, with knowledge or constructive knowledge, has also 8 aided and abetted violations of Section 619 of the San Francisco Police Code, which bans any 9 person in San Francisco from possessing a disassembled magazine with capacity to accept 10 more than ten rounds, by marketing and selling large-capacity magazine conversion kits to 11 individuals in San Francisco; 12 e. ·The Defendants have engaged in fraudulent business practices by overtly or 13 impliedly advertising that California cor,.sumers' purchases of disassembled large-capacity 14 magazines and San Francisco consumers' possession of such magazines are lawful. These 15 advertisements and business practices are likely to deceive reasonable California consumers 16 about the legality of purchasing these products; anc;l 17 f. The Defendants' business practices, as described in this Complaint, constitute 18 unfair business practices because they offend established public policy, and because the harm 19 they cause to consumers and to public safety in California greatly outweighs any benefits 20 associated with those practices. 21 PRAYER FOR RELIEF 22 The People pray for judgment against the Defendants, and each of them, as follows: 23 1. An order by which the Court enjoins each of the Defendants from marketing or selling 24 large-capacity magazine repair kits or any type of disassembled large-capacity magazine to indiyiduals 25 in California, regardless of whether the kits or dissembled magazines are shipped in one or multiple 26 boxes; 27 2. An order that the Defendants state on each website page, social media page, blog post, 28 or any other media advertising, promoting, or selling large-capacity magazine repair kits or an_y type of 15 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirm\li2017\170149\01168095.doc G 0 1 disassembled-large-capacity magazine that: "Under California law, it is illegal for individuals in the 2 state to buy large-capacity magazine 'repair' or 'rebuild' kits or any disassembled large-capacity 3 magazine. Under San Francisco law, it is illegal for individuals in the city to possess these kits or any 4 disassembled large-capacity magazine"; 5 3. An order that the Defendants remove any statements suggesting that large-capacity 6 magazine repair kits or any type of disassembled large-capacity magazine may be legally bought in 7 California or possessed in San Francisco, whether shipped in one or multiple packages; 8 4. An order that Defendants pay $2,500 in civil penalties for each of their acts of 9 unlawful, unfair, and/or fraudulent competition, per California Business and Professions Code section 10 17206(a); 11 5. Costs of suit; and 12 6. For such further and additional relief as the Court deems proper. 13 Dated: February 9, 2017 DENNIS J. HERRERA 14 City Attorney YVONNE R. MERE 15 ~hief of Complex and Affirmative Litigation VICTORIA L. WEATHERFORD 16 AILEEN M. MCGRATH 17 Deputy City Attorneys 18 By. \\ lb -~®- 19 AILEEN M. MCGRATH Attorneys for Plaintiff 20 THE PEOPLE OF THE STATE OF CALIFORNIA, ex rel. San Francisco City Attorney Dennis J. Herrera 21 22 23 24 25 26 27 28 16 PEOPLE v. BADGER MOUNTAIN SUPPLY, INC., ET AL. n:\affirm\li2017\l 70149\01168095.doc 0 0 .EXHIBIT A 1viagazme Kebuild Kits Page 1 of 0 Account I Order srahJs Cont01ctU1 Ghoppmg Car\ f1 d.em1 .:ElfJ .!J .!Ji Er .:I P }.!.J.:J P1•uusl1:1 ~W-V'IJJll tha llWI Jwlimtl':t ~OB 2DVJ JjgJM > Magazine RllbuUd Kita EASY STEPS It is unlawful to ship S!l!Jl!!!m standard capacity magazines to the States llsled below However 11 is legal for us to ship these magazines in the form of rebuild klls as long -tD- as the customer 1s using the rebuild kit to rebuold I repair magazines that he or she legally owned before the Assault Weapon Ban our rebuild klls wiU be shipped C!~M!'!!t unassembled and !here is CU1TenUy a 52 00 fee for each rebuild kit li!!m. To pun:hase our rebulld klts simply click on lhe magazine/s you need then click on lhe checkbox under each magazine that reads "Convert to Rebuild Kit" Add magazine ~~SJ'=\!§, to cart and adjust quantibes VllllY all of our Gun Magezlnes tor Sale ----·---- California: Hawaii: Handgun magazines above 10 rounds will need rebuild kits Maryland: Magazines above 10 rounds wm need rebuild klts Massachusetts: Mag"azines abOve 10 rounds will need rebuild kits New Je111ey: Magazines above 15 rounds will need rebuild kits New York: Magazines above 1O rounds will need rebuild kits On All Gumlf Shooters Ptus Sumran, MS 39462 How to get our $ Cash Price $ On Gunalf Follow us on Dta~b~ok f'.!I ,,.... u• .;.- l a=i_twil:l::~ http://www.shootersplus.com/magazine_rebuild_ kits ? /?!'> f\1 '7 - 0 0 EXHIBITB mi:l~ume repair kits - Ma$~ine repair kits at LAK Supply Page 1 of 0 0 - 2003 EBTD LAK SUPPLY Home :: Mag Repair Kits MAG REPAIR KITS SORT BY: Default B High capacity magazine repair kits at LAK Supply- Ban state tyranny got you down? Don't throw away that broken Magpul Pmag! We offer hicap mag repair kits! LAK Supply offers a wide variety of high-capacity magazines and 1O round magazines for those of you in ban states. We offer a broad range of mags from a variety of manufacturers. Arsenal Bulgarian Circle 1O AK-47 and AK-74 magazines; Magpul Pmags (MOE & Gen M3), ASC, Barrett, Mako, Metalform, BDM and many other AR-15 mag types; pistol magazines from Glock, HK, S&W, ·s1G, Ruger and more. We are your one stop shop for all shapes and sizes of magazines- high capacity magazines, 1 O round magazines, mag loaders, etc. All hi cap magazine orders from ban states will automatically be converted into compliant mag parts kits when you place your order. There is no extra charge, and there is nothing extra to add to your cart. All mag kits are sold for legal use only. If your state of residence has an outright ban on high capacity magazine possession and you must keep as parts only inside your state we expect you to follow the law and do so. If it is legal for you to assemble your kit into a permenantly altered magazine with 10 round or fewer capacity the same applies. Our goal is not to create criminals, rather to assist those of you fighting for your Second Amendment rights in staying compliant while retaining your right to keep and bear arms of the same sort your government has. We will continue to assist those of you as long as it is legally possible for us to do so ... from there it's up to you to change your laws. Calguns Magazine Wiki 10/xx Magazine Discussion Turning a Hi Cap Mag Kit Into a 10 Round Magazine **KIT ORDERS TO CA WILL BE SHIPPED MISSING ONE PART FOR COMPLIANCE Showing 1 - 24 of 52 1 2 3 > http://laksupply.com/magazines-mag-kits 2/1/?017 Magazme repair ki_ts - Magazine repair-kits at LAK Supply Page 2 of 0 0 1911 WILSON GOVT MATCH 8 ROUND 45ACP AK-47 ARSENAL BULGARIAN CIRCLE 10 WAFFLE SSEXTFP 7.62X39 30RD $33.00 $48.00 AK-74 ARSENAL BULGARIAN CIRCLE 10 AR-15ARMATAC150 ROUND SAW MAG DRUM SLABSIDE 30RD 5.45X39 BLK MAGAZINE .223 5.56 $48.00 $433.67 AR-15 ARMATAC SAW MAG 150 ROUND DRUM AR-15 ASC SS 30RD 5.45X39 MOLLE CARRY BAG $19.00 $45.00 http://laksupply.com/magazines-mag-kits ?/1/')l\1'7 1v1agazme repair kits - Magazine repair kits at LAK Supply Page 3 of - 0 0 AR-15 BDM BDM DRUM 50RD .22LR AR-15 LANCER LS.AWM lORD .223 CLEAR $80.00 $19.00 AR-15 MAGPUL ENHANCED FOLLOWER GRN EA AR-15 MAGPUL PMAG GEN M3 30RD .223 BLK $2.00 $14.49 AR-15 MAGPUL PMAG GEN M3 30RD .223 AR-15 MAGPUL RANGER FLOORPLATE GEN M2 WINDOWBLK 5.56 PMAG BLACK *EA $15.95 $4.99 http://laksupply.com/magazines-mag-kits 'l/1/'1nt"' Mag?Zine r_ep_ajr kits - Magazine repair kits at LAK Supj>ly Page 4 of: 0 0 AR-15 MAGPUL RANGER FLOORPLATE 3 PACK AR-15 S&W M&P 15-22 PLINKER TACTICAL GEN M2 5.56 PMAG FOE 35RD.22LR $15.50 $27.00 BERETTA 96 FACTORY lORD 40 S&W BERETTA PX4FACTORY14RD 40SW $40.00 $38.00 BERETTA PX4 SUB COMPACT FACTORY 13RD CZ 75FACTORY12 ROUND MAGAZINE 40SW 9MM $46.00 $40.00 http://laksupply.com/magazines-mag-kits '> 11 nn 1.., .u~5cu.mc: repau tots - Mag~ine repair kits at LAK Supply - Page 5 o 0 0 CZ 75 FACTORY 16 ROUND MAGAZINE 40SW CZ P-07 FACTORY 12 ROUND MAGAZINE 40SW $70.00 $49.00 GLOCK 10MM/45ACP PEARCE GRIP EXT ·1/2 GLOCK 17 33-ROUND OEM HIGH CAPACITY MAGAZINE 9MM $5.97 $40.00 GLOCK 1915-ROUND HIGH CAPACllY GLOCK 2310 ROUND MAGAZINE 40SW MAGAZINE 9MM $26.00 $28.00 Showing 1 - 24 of 52 1 2 3 > FEATURED PRODUCTS -MAG REPAIR KITS http://laksupply.com/magazines-mag-kits 'l /1 '"" 1 .. 1viagazme_~epair kits - Magazine repair kits at LAK Supply Page 6 of - 0 0 AR-15 X PRODUCTS X-15 DRUM MAGAZINE 50 ROUND 223 5.56 $225.00 AR-1s·x PRODUCTS X-15 SKELETONIZED 50 AR-10 ROUND DRUM LR308/SR25 X MAGAZINE 223 PRODUCTS X25 $295.00 SORO SKELETONIZED DRUM 7.62/308 $325.00 AR-10 LR308/SR25 X AR-15 ARMAlAC PRODUCTS X25 150 ROUND SAW 50 ROUND DRUM MAG DRUM MAGAZINE MAGAZINE .223 7.62/308 5.56 $275.00 $433.67 GLOCK 17 33- http://laksupply.com/magazines-mag-kits ?/I 1'>017 Lnc,0cu.1m: repair ktts - Magazine repair kits at LAK Supply Page 7 o1 0 ROUND OEM CAPACITY MAGAZINE 9MM $40.00 AR-15 MSAR XM17GEN 5 TRANSLUCENT SMOKE 30RD .223 SCAR/416 $14.50 GSG-STG44 ATI 25 GLOCK2222- ROUND HIGH ROUNDHIGH ' CAPACITY CAPACITY MAGAZINE 22LR MAGAZINE 40SW $39.00 $40.00 AR-10 X PRODUCTS X-10 50 ROUND DRUM M1A/ M14 MAGAZINE X-PRODUCTS X-14 ARMALITE 308 50 ROUND DRUM 7.62 MAGAZINE 308 $275.00 7.62 $275.00 FN FALX PRODUCTS X-FAL HK91 X 50 ROUND DRUM http://laksupply.com/magazines-mag-kits ')/1 /'){\1 "f 1v1agazme repair kits - Magazine repair kits at LAK Supply Page 8 of PRODUCTS X-91 0 MAGAZINEO DRUM MACHINED MACHINED 308 ALUMINUM SO 7.62 ROUND .308 $275.00 $275.00 WALTHER PPQ AR-15 MAGPUL M217 ROUND PMAGGEN M3 HIGH CAPACITY 30RD .223 BLK MAGAZINE 9MM $14.49 +2BASEPAD $41.19 CONTACT US SITE MAP DISCOUNT COUPONS NEWSLETTER UNSUBSCRIBE SHIPPING & RETURNS PRIVACY NOTICE CONDITIONS OF USE http://laksupply.com/magazines-mag-kits ?/1/?017 0 0 EXHIBITC vi1U1Um~a Mag~ine Rebuild Kit - 7-.62 Precision Page I of: My Account Order Status Wish Lists GiQ ificates View Cart Sign In or Create an account 0 Advanced Search I Search Tips Home Custom Ouracoat Finishes Front Line Holsters Shop by Pistol Contact Us Terms & Conditions Weapon List Products Specl~~tni~ !"fag~~~ ~~~~il~ - ~~!_ ____ --··-·- ______.----~--- Add to Wish List Shop By Pistol Olck the button below to add the California Magazine IWB Concealment Holsters Rebuild Kit ~o your wish list. IWB Tuckable Holsters Pocket Holsters Leather Holsters Kydex Holsters Related Products · New Generation (N.G.) Kydex Double Magazine Holsters Pouch Kydex New Generation ~$29 . 00 (KNGJ holsters Pancake Holsters Concealment Belt Holsters Polymer Magazine Shoulder Holsters Couplers ~$10 . 50 Multl-Purpose Holsters Belt and Paddle Holsters Magazine Pouches Opposite Magazine Price: S 18. 70 Leather Holster Belts Coupler for Two 1Ord Retention Holsters SKU: EARM30CAL Ultlmag Magazines with Two Ultlmags Duty Holsters Brand: E- Lander ~$47 . 35 Tactical Holsters USPS Priority Mall: 52.50 (Fixed shipping cost) '- Ergonomic Folding Pistol Polymer Magazine Grip for Ml 6/M4/AR - 1 5 Pouch with Belt Paddle ~$46.60 for 5.56mm Magazines P.1ot-P.Jtc-d ~s19 _ go Add To Cart Description Similar Products Reviews Also Viewed Ejection Port Cover Small Product Description Parts You Recently E- Lander magazine Rebuild Kits. ~$4 . 65 Viewed ... California Magazine Add To Cart A rebuild kit Includes a complete set of parts that may be used to replace worn or damaged parts on Rebuild Kit other magazines. Shooters In the state of California may use these kits to replace damaged parts on Galli-Style Recoil $18.70 their existing pre- ban magazines. These kits are sold to Callfornta customers for replacement Compensating Folding, o! lot d Collapsible Buttstock parts only, and are not to be used to assemble new functioning magazines within the state of System for vz.58 Callfornla. It Is the customer's responslbillty .to store these kits unassembled until specific parts are removed from the kits and used to repair legal pre- ban magazines, or to build legal 10- round ~S3g3 . 55 ~nt. H~t•d magazines. Add To Cart These parts kits are Intended for California customers only. Any orders for these magazines from 6 Volt 1" Diameter LED locations other than Ca/Jfom/a will be voided. Tactical Weapon Light ~$124 . 55 We will not ship any c~mplete standard capacity AR- 1 5 magazines to the state of California. It Is the ._,o'-Rth"rt responslblllty of the buyer to know and comply with all appllcable local, state, and federal laws Add To Cart pertaining to the possession, use, or transfer of any of these pa~ kits. M16 / M4 /AR- 15 Steel 30 round 5.56mm/ .223 These kits Include: Magazine - Revision 2 White self- leveling anti- tilt follower. Latest generation design built from high- strength polymer with ~$10 . 00 self-lubricating properties. http://www.7-62precision.com/califomia-magazine-rebuild-kit/ 2/1/?017 ...... amurma Magazme l_le~uild Kit - 1.62 Precision Page 2 of. ,.._ot Rlt~J Use to repl ~ er, worn, non- anti-tilt followers in pre- ban magazine etter rellablllty. Add To Cart Compatable\...rf all pre- ban USGI magazines. Our Newsletter Steel magazine body with KTL coating Your Flrst Name: Strong steel magazine body Is compatible with standard USGI magazine parts. May be used to replace bent, dented, or damaged aluminum USGI magazine bodies. Your Email Address: Floorplate Parts Steel reinforced floorplate parts replace the easily damaged floorplates on existing Pre - ban •••••• magazines. Compatible with USGI mag bodies and USGI magazine springs. Extra-power magazine spring Designed for better reliability and popular for tactical or compititlon use, these springs are stiffer and last longer.than standard AR- 1 S magazine springs for better rellabillty. They are comparable to the best aftermarket magazine springs available In the US market. Compatible with USGI floorplates and followers, or use with Included followers and floorplates. All prices are In USO Copyright 2017 7.62 Precision . ~ I Find us on Facebook http://www.7-62precision.com/califomia-magazine-rebuild-kit/ 2/1/?017 - 0 0 EXHIBITD - •U"- .Jv1u \..Jompos1te M~gazine- REBUILD KIT- 7.62x39 TAPCO BLAC<:).14.99: Buymilsurp.com, ... Page I of'. Do You upport the 2nd Amendment? Why you may not want to do business with Wells Fargo, Wachovia, iPayment or Central Payment Corp. Click here for my personal experience Home Log In IEnter search keywords! I Search l Vo r so rce Manufacturers HI CAP MAGAZINES - IN STOCK!!:: AK 30rd Composite Magazine - I Please Select vi Categories LARGO CONCEAL CARRY CLASSES HI CAP MAGAZINES - IN STOCK!! $30 HI CAP MAGAZINES - IN STOCK!! ON-LINE FIREARMS - LOCAL ONLY AK 30rd Composite Magazine - REBUILD FIREARMS - WILL SHIP USA-> KIT - 7 .62x39 TAPCO BLACK DOLLAR BIN $14.99 DISCOUNT BINS-> PPSH 41 & PPS 43 PARTS TAPCO Parts & Accessories-> SKS Rifle Parts & Accessories-> larger Image Masin Nagant Parts & Accessories-> These are "Disassembled" Spare Parts Kits for TAPCO AK-30rd Rifle Parts & Accessories-> Magazines- Pistol Parts & Accessories-> NOT AS PICTURED, These are sent as 5 individual Parts Ammunition-> Misc. Accessories-> Scopes Mounts & Optics-> OK TO SHIP TO CA Shooting Supplies & Safety-> Florida Conceal Carry Permit Component of the INTRAFUSE™ AK Stock System. The riew TAPCO Stripper and Loading Clips 30rd AK magazine offers the next generation of technology to feed .SO Caliber Once Fired Brass your Kalashnikov. Designed with horizontal exterior grooves to 26.5 FLARE GUN SUB CAL. INSERT offer increased styling and gripping surface, our magazine features a heavy duty spring and an anti-tilt follower for increased Booklets and Manuals reliability. Constructed of reinforced composite with a metal Daisy VL Ammo for Sale floorplate. For 7.62 x 39 mm ammo. The magazine counts as 3 MISC GUN SPRINGS Sec. 922r compliant parts (when inserted into your rifle) and is Ordnance, Grenades & Rockets backed by TAPCO's lifetime guarantee. RECOIL BUFFERS Surplus Firearms Virtual Museum-> MORE BY MANUFACTURER-> o Model: TPCO AKJO REBUILD KIT • Shipping Weight: libs New Products ... • 0 Units in Stock Featured Products ... • Manufactured by: TAPCO All Products ... ~ntersearch keywornsl l Search I This product was added to our catalog on Sunday 30 December, 2012. https://www.buymilsurp.com/ak.-30rd-composite-magazine-rebuild-kit-762x39-tapco-black-p-42852.html 2/1/2017 ru" .Juru ~omp_os1te Magaz~ne - REBUILD KIT ~ 7-.62x39 T APCO BLAC $14.99: Buymilsurp.com,... Page 2 of Information 0 Customers who bought s product also purchased ... Shipping & Returns Privacy Notice Conditions of Use AK Magazine Clamps (4 Contact Us I I Pack Site Map II~ Axis Pin AK Rifle Gift Certificate FAQ Stripper Clips 10 rd Discount Coupons Original SKS & AK Rifles Newsletter Unsubscribe OTY20 Important Links My FFL fe,>r Transfers Florida Gun Show Calendar Courtesy of NextGunShow.com Why you shouldn't Do Business with AK SAW Style Pistol Grip Sight Tool Windage & Pouch AK Holds 3-30RD Central Payment, Wells Fargo Black, OD or Dark Earth - Elevation SKS and AK Rifles Ma azines Romanian SurplusFlrearms.com TAPCO Home Your IP Address is : 108.208.54.34 Co ri ht © 2017 Bu milsur .com Online Store. Powered b Zen Cart Parse Time: 0.345 - Number of Queries : 330 - Query Time: 0.0706141551514 https://www .buymilsurp.com/ak-30rd-composite-magazine-rebuild-kit-7 62x39-tapco-black-p-42852.html 2/1/?017