The case wasn't about guns that never had a serial number, it was about guns which the numbers were removed.
A gun which never had numbers, that isn't one of the "dangerous" classes, would be protected. If you make your own pistol out of a block of metal and never assign it a serial number, or buy a pre-'68 GCA gun without numbers, it would be as protected as a new Ruger GP100 would be.
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