Franklin Armory’s Antithesis Quickly Infringed

Life comes at you fast. By the time we published our article about the Franklin Armory Antithesis, the ATF asked the company to bring back 5.56×45mm Antithesis units pending a new classification. Franklin Armory says it’s voluntarily requesting returns for a full refund on those 5.56 models.

The Antithesis is one of Franklin Armory’s designs intended to live outside the NFA by exploiting the statute’s definitions. It’s a stock-equipped, short-barreled firearm that Franklin Armory represented as designed to fire both single-projectile and multi-projectile ammunition (e.g., .410 shotshells, slugs, and .45 Colt)—which is central to its classification fight.

Under 26 U.S.C. § 5845(c), a rifle is (among other elements) a shoulder-fired weapon “designed… to fire only a single projectile through a rifled bore for each single pull of the trigger.” Franklin Armory argued that because Antithesis is designed to fire multi-projectile ammunition as well (e.g., .410 shotshells), it is not a “rifle,” and therefore not an SBR under the NFA. (Shotgun, by contrast, is defined as smoothbore and may fire “a number of projectiles (ball shot) or a single projectile.”)

It was first announced in 2018, and after years of being stuck in legal hell, Franklin Armory seemed to have scored a major win for the Antithesis. Earlier this year, Judge Daniel M. Traynor ruled in the Eighth Circuit Court of Appeals.

On February 18, 2025, U.S. District Judge Daniel M. Traynor (District of North Dakota) granted summary judgment for FRAC and Franklin Armory in FRAC & Franklin Armory v. Garland (later captioned v. Bondi), vacating ATF’s prior misclassifications of Reformation and Antithesis. In that order, Judge Traynor wrote:

Franklin Armory designed the Antithesis to fire multiple kinds of ammunition. The weapon does not fire only a single projectile. Firing multiple projectiles is not incidental or a by-product. The Antithesis is a square peg and calling it round will not change how it fits into the round hole of these statutes. Therefore, ATF exceeded its authority by not giving the plain meaning to the words of the statute.

Following the settlement, the ATF issued an open letter on August 29, 2025, rescinding a 2019 Reformation letter and addressing both Reformation and Antithesis. In describing Antithesis, ATF noted it “utilizes a 14.5-inch rifled barrel to fire .410 bore shotshells and slugs, in addition to .45 Colt cartridges” and acknowledged that its prior classification was vacated.

As a result of the Agreement, the Antithesis is not a rifle, short-barreled rifle, nor is it an NFA firearm; therefore, (i) no NFA forms are necessary to sell, transfer, transport, deliver, or otherwise deal in or possess the Antithesis, and (ii) no ATF Form 5320.20, Application to Transport Interstate or to Temporarily Export Certain National NFA Firearms, is necessary to transport the Antithesis across state lines because the firearm is not subject to 18 U.S.C. § 922(a)(4) or (b)(4).

Clear enough, right? Not so fast. Shortly after Franklin Armory put the Antithesis—chambered in 5.56×45mm NATO—on the market on September 17, 2025, the ATF issued a statement on X (edited to merge multiple posts into a single statement):

On August 29, 2025, ATF issued an open letter reclassifying Franklin Armory’s Reformation and Antithesis. The open letter implemented a settlement agreement, which classified these weapons as “firearms” under the Gun Control Act but not subject to the controls of the NFA. The open letter only applies to the two models listed in the letter, in the specific configuration that was the subject of the settlement agreement. Other short-barreled firearms are not covered by the settlement agreement, even if they are being branded as “Reformation” or “Antithesis” firearms.

The ATF publicly emphasized that the letter applies only to the specific models/configurations covered by the settlement—not to “other short-barreled firearms,” even if branded “Reformation” or “Antithesis.”

Let’s return to the ATF’s August letter, which states early on:

Separately, FATD examined the Antithesis firearm for classification under the GCA and the NFA. The Antithesis is a type of firearm that utilizes a 14.5-inch rifled barrel to fire .410 bore shotshells and slugs, in addition to .45 Colt cartridges. As such, FATD classified the Antithesis as a shortbarreled rifle under both the GCA and the NFA. This classification was vacated.

In plain English, my interpretation of what the ATF is saying is: “Nice try, Franklin Armory, but we said the Antithesis falls outside the bounds of the NFA only if it’s chambered in .410 / .45 LC. We didn’t say you could just go ahead and sell this thing chambered in 5.56×45mm NATO because then it’s clearly a rifle because then there’s no confusion over how many different kinds of projectiles it can shoot.”

Now it appears that the ATF is requesting a new classification for firearms like the Antithesis, and asking Franklin Armory to recall models that have already been sold. In a statement, Franklin Armory said:

Last night, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) requested that we voluntarily bring back all 5.56 caliber Antithesis firearms in advance of the agency issuing a new classification. We were surprised by this in light of the U.S. District Court’s ruling in FRAC v. Bondi.

Out of an abundance of caution and for the well-being of consumers, dealers, and distributors, we are voluntarily requesting all of our customers to return their 5.56 caliber Antithesis firearms for a full refund.

We encourage customers who have taken possession of an Antithesis firearm to contact Franklin Armory Customer service for an RMA (Return Merchandise Authorization) and shipping label. This return does not affect Reformation, the .410/45LC Antithesis, or any other firearm made by Franklin Armory.

Franklin Armory clarified that the recall does not affect Reformation, the .410/45LC Antithesis, or any other firearm made by Franklin Armory.

So the confusing drama of the Antithesis continues. Of course, Franklin Armory declares that they will continue to fight.