William R. Mills
										2562 N. Dewey Ave.
										Fresno, CA 93722

Bureau of Alcohol, Tobacco and Firearms
Technology Branch, Room 6450
Attn: Chief Ed Owen
650 Massachusetts Ave.
North West Washington D.C. 20226

Chief Owen,

For some time now, I have been considering the construction of a device to quiet the report of a 
paint pellet gun for personal use in the sport of paintball.  From my present understanding of 
federal regulations this is a legal endeavor.  It has come to my attention that some previously 
produced paintgun sound suppressors have been declared illegal because they also functioned as 
firearms sound suppressors.  In order to further understand the federal regulations governing 
firearms sound suppressors so that I might build a paintgun sound suppressor which would not 
also be considered a firearms sound suppressor, I made a phone call to the Fresno Bureau 
office, and Agent Bob Christopherson suggested I write this letter to you for further 
clarification and information.

I have recently come across an idea for producing a paintgun sound suppressor which would not 
suppress the sound of a firearm, and hopefully therefore, not be classified as a firearms 
silencer.

In recent years, several of the manufacturers of aftermarket paintgun barrels have been 
producing designs which are heavily ported.  By drilling vent holes into the barrel, many of the 
propellent gasses (CO2, N2, or compressed air) are released out the sides, rather than in a 
turbulent burst at the muzzle, which tends to de-stabilize the paint pellet's trajectory.  Some 
models begin this porting as far back as 1/3 of the barrel length away from the breach.  As a 
side effect of the barrel porting, the report of the paintguns equipped with such barrels is often 
significantly less than that of a similar paintgun with a solid barrel.

It occurred to me that it would be rather simple to further suppress the report coming out of such a paintgun barrel by capturing and deadening the gas escaping from the barrel vents. This idea is shown in the diagram labeled "paintgun sound suppression device".


Since this device is dependant on the vents in the paintgun barrel to deaden the sound, it would 
not decrease the report of an actual firearm, when fitted over the barrel.  As this design also 
depends on a friction fit at both the front and back ends, it could not be fitted as an extension 
onto the end of a firearm barrel either.

I am interested in whether or not a device of such design would be considered to be a firearm 
sound suppressor, and the reasons why or why not.  I would also appreciate any other specific 
information you could provide me with, such as text of the applicable laws which define what 
is, and what is not a firearm silencer, as well as any laws which my be applicable to quieting the 
report of a paintpellet gun.

From my conversation with agent Christopherson, I understand that before constructing the 
paintball sound suppressor I have described (assuming it is not considered a firearm silencer 
under federal law) I will also need to check to make sure it does not violate any state or local 
regulations.

Thank you for your assistance in this matter,
[signature]

William Mills