“Is it legal? YES! The Polymer80 G150 unit is well within the defined parameters of a ‘receiver blank’ defined by the ATF and therefore has not yet reached a stage of manufacture that meets the definition of firearm frame or receiver found in the Gun Control Act of 1968 (GCA).”

💡 This prominent false statement misled D.C. consumers into believing Polymer80 products were legal when they violated multiple local gun laws

“The Court finds that the statement is a false representation because it (1) represented that the Polymer80 G150 firearm had approval in the District of Columbia when it did not, (2) represented that Polymer80 had approval or certification to sell the firearm to District consumers when it did not, and (3) represented that District consumers would have gained the right to possess the firearm if they purchased the firearm on Polymer80’s website.”

💡 The court identified three distinct false representations in a single statement, showing deliberate deception across multiple dimensions

“In the instant case, Polymer80 sold unfinished handgun frames, unfinished semi-automatic receivers, and Buy, Build, Shoot kits to District consumers, and these products are (and were) readily converted into firearms.”

💡 The court rejected Polymer80’s core defense that its products were not firearms, finding they met the legal definition of readily converted weapons

“Polymer80 itself demonstrates just how readily convertible its unfinished handgun frames, receivers, and Buy, Build, Shoot kits are. On Polymer80’s website, they provide instructions to consumers on how to build firearms with these unfinished frames, receivers, and Buy, Build, Shoot kits. Polymer80 also provides links to YouTube videos that provide instructions on how to complete the assembly of the firearms.”

💡 Polymer80’s own marketing materials proved the products were designed to be easily converted into functioning firearms

“Polymer80 violated District law by selling firearms to District consumers without the requisite licenses, and failing to comply with the series of restrictions and requirements the District imposes on licensees. Additionally, Polymer80’s firearms violated District law because the firearms were not registered and failed to have an identification number or serial number.”

💡 Polymer80 bypassed every major gun safety requirement designed to protect D.C. residents from untraceable weapons

“Additionally, according to the District, Polymer80 sold 19 firearms to District consumers without being licensed in the District to sale firearms, without conducting a background check on consumers, and without the firearms having serial numbers.”

💡 These 19 documented sales represent direct evidence of illegal firearms transactions with no safety checks or traceability

“According to the Plaintiff, from at least January 16, 2017 through June 24, 2022, Defendant prominently advertised on its homepage and FAQs page that its products were legal.”

💡 Polymer80 maintained false advertising for over five years, showing sustained and deliberate deception rather than an isolated mistake

“The CPPA protects consumers from unlawful trade practices enumerated in § 28-3904, as well as practices prohibited by other statutes and common law.”

💡 This legal principle allowed D.C. to use consumer protection law to address gun law violations, expanding enforcement options

“Given the Court’s ruling that Polymer80 violated the CPPA and the District’s gun laws, and Polymer80’s alarming belief that the sale of its firearms is now legal in the District, to prohibit future sales of its firearms to District consumers, the Court shall grant the Plaintiff’s request for a permanent injunction.”

💡 The court found Polymer80’s continued insistence its products are legal so concerning it required a permanent injunction to protect public safety

“Under the CPPA, it is a violation for any person to engage in an unfair or deceptive trade practice, whether or not any consumer is in fact misled, deceived, or damaged.”

💡 D.C. law recognizes that deceptive practices harm the public interest even if individual consumers are not provably deceived

“Both the FCRA and GCA include specific language that defines firearms as readily converted weapons, regardless of their operability.”

💡 The court rejected Polymer80’s argument that unfinished frames were exempt from the readily converted standard

“From the time Polymer80 sold its first firearm to a District consumer on March 17, 2017 to July 16, 2017 (the day before section 28-3909(b)(1) was amended), Polymer80 engaged in unfair and deceptive trade practices, by making false representations to District consumers on its website, for 488 days. From July 17, 2017 to June 24, 2020 (the day the District filed its Complaint), Polymer80 continued to engage in unfair and deceptive trade practices for another 710 days.”

💡 The court calculated penalties for each day false statements appeared on the website, totaling 1,198 violations over more than three years

“If the Attorney General for the District of Columbia has reason to believe that any person is using or intends to use any method, act, or practice in violation of section 28-3904, and if it is in the public interest, the Attorney General, in the name of the District of Columbia, may bring an action in the Superior Court of the District of Columbia to obtain a temporary or permanent injunction prohibiting the use of the method, act, or practice and requiring the violator to take affirmative action.”

💡 The law empowers enforcement action to protect the public interest, not just compensate individual victims

“However, this Court is not bound by the ATF’s interpretation of the GCA.”

💡 The court rejected Polymer80’s reliance on federal agency determinations that conflict with local public safety laws

“An alleged unfair trade practice is considered in terms of how the practice would be viewed and understood by a reasonable consumer.”

💡 The legal standard focuses on how ordinary people would interpret Polymer80’s statements, not narrow technical readings