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If you think of a traditional bolt action rifle, the serialized portion of the gun is the barreled action. So now the ATF is saying a bolt action upper assembly should be classified as such regardless that it sits on a serialized AR lower.
Near the end of the letter the ATF goes on to say they have previously determined that non-standard AR type upper receivers are considered firearms even when attached to an AR-type receivers.
"Arms discourage and keep the invader and plunderer in awe, and preserve order in the world as well as property. . . Horrid mischief would ensue were the law-abiding deprived of the use of them."
- Thomas Paine
"Malo periculosam, libertatem quam quietam servitutem."