Update on Operations and Product Offerings

We listened to the oral arguments regarding Final Rule 2022-0F5 since solvent traps were mentioned in the comments section—a product we proudly offer and market as solvent traps since our company sells solvent traps.

After reviewing the discussions, we observed that our products were not referenced at any point during the oral arguments. From what we understand from all this confusion is that solvent traps were not referenced in the section of the rule labeled ‘V. Final Rule’. The focus of the rule is on classifications of firearms, firearm parts, or weapons kits, as the solicitor general clearly confirmed. These are topics that we do not have expertise in, these are not products we sell, nor are they processes or operations we engage in.

The mention of ‘solvent traps’ in the comments section seems intentionally misleading, oddly mentioning solvent traps specifically. This adversely affects legitimate businesses like ours that sell these items for lawful firearms cleaning and storage solutions. The mentioning of legal products by name in the comments area of a final rule causes confusion and creates a negative perception of our products to consumers; a clear goal of this administration. The clear purpose, design and intended use of our products are and have always been lawful, and now that the government was forced to answer questions from the supreme court, it provides more clarity for us.

Additionally, our solvent trap products are not weapons which are defined in the arguments as instruments of combat designed and intended to be used for offensive or defensive combat. Clearly, our products are not designed or intended or marketed for combat, and our operations, communications or instructions are evidence of this.

While solvent traps were not directly addressed in the Final Rule itself (V. Final Rule), we made the prudent decision to temporarily pause operations to assess the rule’s implications. The oral arguments helped clarify many uncertainties, as questions raised by justices had to be answered by the lawyers involved.

The conclusion appears to be clear: this rule is focused on companies selling parts kits for constructing firearms, weapons parts kits and associated modifications which is irrelevant to our products. These topics do not pertain to our offerings or operations. Our products do not include tools, instructions for modification, nor do they require any alterations to be used properly for their intended use as cleaning and storage products, as outlined in our product instructions.

It is the responsibility of the ATF and DOJ to clarify their stance, especially since they chose to specifically mentioned solvent traps in the comments area of the Final Rule. Their failure to do so within their vague rule is irresponsible. Nonetheless, we chose to act responsibly and paused our operations for almost 3 years to protect our customers from bias agency interpretations.

Our solvent trap products and accessories are designed and intended to be used for firearms cleaning and storage solutions and based on their traditional design, intent, instructions and absent of any ‘tools for medication’ means any other interpretation would be ridiculous. Now that we have oral arguments recorded and documented, we are comfortable with resuming the sales of solvent trap products and lawful business operations.

Even if solvent traps were mentioned during oral arguments, the concerns regarding companies selling products with tools and instructions for modification do not pertain to Armory Den’s offerings or operations. Our business practices are firmly against such activities and this is communicated in bother public and private communications on our website and with our customers.

It is our opinion that the oral arguments have further affirmed that our business is one that would not be subject to issues because we sell a legal product for legal purposes with instructions on how to use them. This is why Armory Den has remained operational until our decision to pause for further clarity on this rule. We would still be operational today if it were not for our team becoming aware of  ‘solvent traps’ being referenced in the comments section of the rule.

We acknowledge that some individuals and businesses may try to sell products that are illegal or engage in ill-intended business transactions, a reality present in many markets. However, allowing federal agencies to overreach and impose vague regulations can severely impact legitimate businesses such as ours.

As the justices pointed out, establishing clear guidelines is crucial. This clarity is necessary to prevent individuals and companies like ours from being unfairly targeted by ambiguous regulations that can enable agencies to undermine businesses based on personal biases or negative perceptions fostered by unethical actors in the industry. This is important, because it gives agencies authority to target businesses they want, and not businesses that are engaging in illegal activity – another important reason for Armory Den to pause in operations.

Over the years we have invested marketing, development and other online assets and resuming operations with this oversight and authority can compromise our time, investment, and effort simply due to the opinions of bureaucrats.

We do not presume that all ATF agents and DOJ lawyers harbor malicious intent towards businesses, as decisions often stem from broader administrative directives. Nonetheless, federal rules should not be crafted under the assumption that all companies selling solvent traps have improper motives. We are clear evidence that our company is a legally operating business as we still have full ownership of all our assets and domains.

As a result of our evaluation, Armory Den plans to resume operations between 2024 and 2025. Due to the confusion stemmed from solvent traps being mentioned in contents of a new regulation and their financial implications, our product offerings and support will be limited. Support will be offered and products will release when the time permits and circumstances allow.

We look forward to expanding our product line and releasing more products as time permits and circumstances allow.

In the meantime, we have updated our product guides with a fresh new look which will only include instructions that use of products that align with our limited release. Products guides will be updated and new product guides will be released based on time products released to provide additional value, benefits, and uses of our cleaning and storage products when they become available.

Thank you for your understanding and patience.

– Armory Den Team