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Yep, as far as the feds are concerned, if it doesn't use fire then it's not a "firearm". If it does use fire then it MAY be a firearm.
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And then it may depend on which law you're reading, and what the context is. Many laws include their own definitions, either at the start or at the end, and a definition from one law may not be applicable to another law -- especially if the other law includes its own definitions.