Here is Bardwell's explanation of ATF's ruling:
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If the registered conversion part breaks or wears out it cannot be replaced, only repaired, if possible. BATF considers replacing it with a new part to be the new manufacture of a machine gun, and a civilian could not own it, as it would have been made after the effective date of 18 U.S.C. sec. 922(o). This wear/breakage thing is also true of the receiver on a gun where that is the registered part, but in general the receiver is less subject to wear or breakage than a small part, like a sear. Being larger, a receiver may also be easier to repair.
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