Pennsylvania has already lost a major Second Amendment battle over the rights of 18-to-20-year-old adults, but the state continues to enforce a law that prevents those same adults from obtaining a license to carry firearms. Now, the Firearms Policy Coalition (FPC) and National Rifle Association (NRA) are back in federal court, demanding an immediate end to Pennsylvania’s unconstitutional age restriction.
FPC and the NRA are challenging Pennsylvania’s refusal to issue firearm carry licenses to otherwise eligible adults ages 18 to 20. iStock-2202560895
On November 2, 2026, FPC and the NRA filed a motion for a preliminary injunction or, alternatively, summary judgment in Maines v. Bethel, asking the U.S. District Court for the Eastern District of Pennsylvania to block the state’s prohibition on issuing carry licenses to adults under 21. The motion follows an October 29 lawsuit challenging Pennsylvania’s continued refusal to recognize the full Second Amendment rights of otherwise law-abiding young adults.
The case presents a straightforward constitutional question: How can Pennsylvania continue denying carry licenses to 18-to-20-year-olds when a federal appeals court has already ruled that those adults are among “the people” protected by the Second Amendment?
Pennsylvania’s Carry Ban Makes Young Adults Second-Class Citizens
Under 18 Pa.C.S. § 6109(b), only individuals 21 or older may apply for a Pennsylvania license to carry firearms. That restriction has serious consequences because state law generally requires a license to carry a concealed firearm, carry a firearm in a vehicle, or carry openly or concealed on Philadelphia’s public streets.
Although Pennsylvania generally permits unlicensed open carry outside Philadelphia, that right becomes considerably less useful when an adult cannot lawfully carry a handgun in a vehicle. For young adults who rely on a vehicle for work, school, shopping, or other everyday activities, Pennsylvania’s licensing restriction creates substantial obstacles to exercising their constitutional right to armed self-defense.
The lawsuit was brought by Philadelphia resident Daniel Maines, FPC, and the NRA against Philadelphia Police Commissioner Kevin Bethel and Pennsylvania State Police Acting Commissioner George L. Bivens.
According to the October 29 complaint, Maines is between 18 and 20 years old, legally eligible to possess and acquire firearms, and has no criminal record. He wants to carry a handgun for self-defense, including while traveling in a vehicle and throughout Philadelphia. He is also a member of both organizations bringing the lawsuit.
Maines can vote, enter contracts, marry, and enlist in the military. Pennsylvania nevertheless refuses to allow him to apply for a carry license solely because he has not reached his 21st birthday. The state has effectively created two classes of legal adults, granting one the ability to exercise its right to carry while denying that same opportunity to the other.
The consequences are not limited to a rejected permit application. Carrying a firearm without the required license can expose an individual to criminal prosecution, including felony charges under certain circumstances. The restriction also intersects with the federal Gun-Free School Zones Act, which generally prohibits firearm possession within 1,000 feet of school grounds unless an applicable exception applies. By denying carry licenses to younger adults, Pennsylvania also prevents them from qualifying for the federal law’s state-license exception.
Pennsylvania Already Lost This Fight in the Third Circuit
The new lawsuit builds directly on FPC’s earlier victory in Lara v. Commissioner Pennsylvania State Police, a case challenging Pennsylvania’s prohibition on open carry by 18-to-20-year-olds during declared states of emergency.
In January 2025, the U.S. Court of Appeals for the Third Circuit reaffirmed its ruling that young adults are protected by the Second Amendment and that Pennsylvania had failed to establish a historical tradition justifying the challenged age-based restriction. The U.S. Supreme Court denied Pennsylvania’s petition for review on June 30, 2026, leaving the appellate court’s decision in place.
The Third Circuit recognized that 18-to-20-year-olds are presumptively included among “the people” whose rights the Second Amendment protects. That finding is central to the new lawsuit. While Lara addressed a different carry restriction, FPC and the NRA argue that its constitutional reasoning leaves Pennsylvania without a legitimate historical justification for continuing to deny carry licenses to otherwise eligible adults under 21.
The historical record presents another problem for Pennsylvania. At the Founding, young men were expected to possess arms and participate in militia service. The federal Militia Act of 1792 required eligible men beginning at age 18 to enroll in the militia and equip themselves with firearms. Yet Pennsylvania now insists that adults of the same age cannot even apply for permission to carry a handgun for personal protection.
Under the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, the government must demonstrate that a restriction on conduct protected by the Second Amendment is consistent with the nation’s historical tradition of firearm regulation. The Third Circuit’s decision in Lara identified no founding-era statute restricting the freedom of 18-to-20-year-olds to carry firearms.
Pennsylvania cannot simply disregard that history because lawmakers prefer a different minimum age. Constitutional rights are not privileges that the government gets to distribute according to its own preferences.
FPC and NRA Demand Immediate Relief
FPC President Brandon Combs made clear that the organization has no intention of allowing Pennsylvania to continue enforcing the restriction while another lengthy legal battle unfolds.
“Pennsylvania has already lost this constitutional fight twice in the Third Circuit, and the Supreme Court refused to bail it out,” Combs said in FPC’s November 2 announcement.
Combs also condemned the legal consequences facing young adults who attempt to exercise their constitutional rights without a license the state refuses to issue.
“That’s not a technicality. It’s an immoral, government-created trap that threatens Americans with prison for exercising their rights.”
The plaintiffs are asking the district court to issue a preliminary injunction preventing enforcement of the challenged age requirement while the case proceeds. Alternatively, they want summary judgment in their favor, arguing that the governing constitutional principles have already been established and that another prolonged legal fight is unnecessary.
The lawsuit also reflects a broader effort to dismantle age-based restrictions on the right to keep and bear arms. In Worth v. Jacobson, the Eighth Circuit struck down Minnesota’s prohibition on issuing carry permits to 18-to-20-year-olds. In Reese v. ATF, the Fifth Circuit rejected the federal government’s prohibition on licensed firearm dealers selling handguns to adults under 21. Both decisions reinforce the growing judicial rejection of laws that treat otherwise eligible young adults as second-class citizens when it comes to the Second Amendment.
Firearms Policy Coalition
Pennsylvania’s carry-license restriction is another example of government officials treating the exercise of an enumerated constitutional right as a privilege that begins whenever lawmakers decide it should. The Third Circuit has already recognized that 18-to-20-year-olds are protected by the Second Amendment. The remaining question is whether Pennsylvania can continue denying those adults a practical means of exercising their right to carry firearms for self-defense.
An American does not become a member of “the people” on his 21st birthday. The right to keep and bear arms belongs to legal adults at 18, and Pennsylvania has no constitutional authority to withhold that right for another three years.
The case is Maines v. Bethel, No. 2:26-cv-08301-CMR, in the U.S. District Court for the Eastern District of Pennsylvania.
Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.
A Virginia judge has expanded a preliminary injunction against the state’s restrictions on commonly owned semiautomatic firearms and standard-capacity magazines. IMG Duncan Johnson
Virginia gun owners have secured another victory in court as a judge expanded an existing injunction against Gov. Abigail Spanberger’s ban on commonly owned semiautomatic firearms and standard-capacity magazines. The latest ruling extends the court’s order beyond the Virginia State Police to the Commonwealth itself, its agencies, and its employees.
On November 2, Lancaster County Circuit Court Judge John S. Martin entered an order in Crump v. Katz, Case No. CL26000201-00, partially granting the plaintiffs’ second motion to enlarge the preliminary injunction. The ruling broadens the reach of an injunction that has already prevented enforcement of Virginia’s controversial restrictions on AR-15-style rifles and magazines holding more than 15 rounds.
The Commonwealth opposed the expansion, but Judge Martin granted it anyway.
Virginia’s Gun Ban Faces Another Courtroom Setback
The lawsuit challenges Senate Bill 749, signed into law by Gov. Abigail Spanberger in May. The legislation targets firearms the state labels “assault firearms,” including commonly owned semiautomatic rifles, and prohibits certain transactions involving magazines capable of holding more than 15 rounds.
For gun owners, these are not exotic or unusual weapons. AR-15s are among America’s most popular rifles, used for self-defense, competition, recreational shooting, and other lawful purposes. Magazines holding more than 15 rounds are standard equipment for countless firearms owned by ordinary Americans.
The lawsuit, brought by AmmoLand contributor John Crump and gun rights organizations including Gun Owners of America, Gun Owners Foundation, Virginia Citizens Defense League, and Virginia Citizens Defense Foundation, argues that the restrictions violate Article I, Section 13 of the Virginia Constitution, which declares that the right of the people to keep and bear arms shall not be infringed.
In June, Judge Martin issued a preliminary injunction blocking enforcement of the challenged restrictions through December 31, 2026, or until further court action. The injunction was a major setback for Virginia officials who intended to begin enforcing the restrictions on July 1.
The latest order addresses another important question: who, exactly, is bound by that injunction?
Judge Extends Injunction to the Commonwealth and State Agencies
The original case named Virginia State Police Superintendent Jeffrey S. Katz as a defendant. The plaintiffs subsequently sought to expand the injunction’s reach, ensuring that enforcement could not simply shift to other state authorities.
Following an October 20 hearing, Judge Martin granted part of that request.
The November 2 order states:
“Plaintiffs’ Motion is GRANTED to the extent that the Commonwealth of Virginia, its agencies and employees are hereby preliminarily enjoined subject to the same terms and duration outlined in the Preliminary Injunction entered June 30, 2026 and Order entered September 10, 2026.”
The court denied the motion in all other respects.
Virginia’s attorneys, Assistant Attorneys General Calvin C. Brown and Pebbles I. Burgess, expressly objected to the portion of the order extending the injunction to the Commonwealth, its agencies, and officials.
The distinction matters. The ruling does not create a new permanent injunction or finally strike down the gun ban. It expressly extends the existing preliminary relief to additional state defendants while preserving the terms established by the court’s previous orders.
It also does not expressly identify every local sheriff, police department, or Commonwealth’s Attorney as a newly enjoined party.
Nevertheless, the Commonwealth’s attempt to resist the expansion failed.
Virginia’s Gun Ban Heads Toward a Larger Constitutional Reckoning
The ruling comes as the U.S. Supreme Court prepares to hear arguments in the consolidated cases Viramontes v. Cook County and Grant v. Higgins on December 2, 2026. Those cases directly confront whether bans on AR-15-style rifles and similar semiautomatic firearms violate the Second Amendment.
Virginia’s restrictions strike at the heart of the constitutional protections recognized in District of Columbia v. Heller, which affirmed that firearms commonly possessed by law-abiding Americans for lawful purposes fall within the Second Amendment’s protection.
Virginia politicians may dislike AR-15s, but political opposition does not erase constitutional rights. The government cannot transform commonly owned firearms into unprotected weapons simply by attaching the politically manufactured label “assault weapon.”
For now, the litigation in Crump v. Katz continues, and Judge Martin’s latest order strengthens the existing injunction by expressly bringing Virginia’s state agencies and employees within its reach.
The fight to permanently defeat Virginia’s gun ban is far from over, but the Commonwealth has suffered another setback in its effort to enforce restrictions on firearms and magazines that Americans have every right to own.
Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.
Guns have costs. They also have benefits. An honest public-policy debate has to count both.
Firearms serve millions of Americans as tools for self-defense, recreation, training, and constitutional freedom. The benefits of lawful gun ownership deserve consideration alongside the costs of criminal misuse. iStock-119502436
More than a decade ago, I wrote an article called The Social Utility of Firearms. My point was fairly simple: much of the gun-control debate looks through the wrong end of the telescope. It focuses intensely on the harms associated with firearms while routinely ignoring, minimizing, or simply assuming away the benefits that lawful firearm ownership provides.
Twelve years later, I would change some of the statistics in that article. We have better data now. Some empirical questions remain genuinely disputed. And I would be more cautious today about several broad claims—particularly concerning suicide and the precise number of defensive gun uses. But the central problem I identified in 2014 remains.
When policymakers talk about the “cost” of private gun ownership, they count virtually everything: homicides, suicides, accidents, medical expenses, police costs, fear, psychological consequences, lost productivity. When they discuss the other side of the ledger, however, the accounting often stops. What is the value of a woman who prevents a sexual assault by displaying a handgun without firing it? What is the value of a store owner who persuades an armed robber to flee? What is the value of the homeowner whose firearm causes an intruder to leave before anyone is injured? What is the value of an armed citizen who stops an attacker before the incident becomes a mass killing? Those events have social utility too. You cannot conduct a serious cost-benefit analysis while entering every debit and refusing to record the credits.
Start With the Costs Honestly
There is no reason for Second Amendment advocates to pretend firearms cannot be misused. CDC data show 44,447 firearm deaths in the United States in 2024. Of those, 27,593 were suicides. There were 15,364 firearm homicides. Those are serious numbers and serious human tragedies.
But even those numbers illustrate why precision matters. Suicide and criminal homicide are different social problems. They have different causes, different perpetrators, different victims, and potentially different solutions. Combining them under the rhetorical heading “gun violence” may be politically useful, but it can obscure more than it explains.
I would also modify something I argued too categorically in 2014. I wrote then that suicidal people deprived of a firearm would simply substitute another method. The current research does not justify stating the proposition that broadly. Firearms can be highly lethal, and easier access to a particular method can matter during a suicidal crisis. Firearm suicide therefore deserves to be confronted seriously.
But that does not mean every firearm restriction is an effective suicide-prevention measure. A policy directed at a suicidal person during a period of acute crisis; secure firearm storage, mental-health intervention, or temporary separation from lethal means raises a very different policy question from banning a commonly owned rifle or imposing burdens on millions of people who present no suicide risk. Honest analysis requires separating problems rather than using the overall number of “gun deaths” to justify whatever gun-control proposal happens to be on the legislative agenda.
Defensive Gun Use: Measured Differently, Not Unmeasurable
The most obvious social benefit of firearm ownership is defensive use, and this is where the statistical argument becomes especially interesting. There is no universally accepted number for defensive gun uses in America.
A National Academies report commissioned as part of the federal government’s post-Sandy Hook firearms-research initiative described defensive gun use by crime victims as a “common occurrence,” while emphasizing that estimates varied substantially. It summarized national-survey estimates ranging from roughly 500,000 to more than 3 million defensive uses annually, while also discussing much lower estimates derived from the National Crime Victimization Survey.
More recently, William English’s National Firearms Survey estimated approximately 1.67 million defensive firearm uses annually. His survey found something especially important: in more than 80 percent of reported defensive incidents, the defender did not fire the gun.
GunFacts has collected the results of numerous defensive-gun-use surveys conducted over the years. According to GunFacts, those survey estimates average just under two million defensive gun uses per year. Individual estimates vary considerably, but that variation does not mean defensive gun use cannot be measured. It means researchers are not always measuring exactly the same thing in exactly the same way.
Some surveys ask only about defensive uses connected with a recognized crime. Others ask more broadly whether a firearm was displayed, mentioned, retrieved, or otherwise used to protect a person or property. Some use different recall periods. Some employ different screening questions. Researchers also differ in how they define a qualifying defensive use and in the populations they survey. Question wording, screening criteria, survey populations, definitions, and methodology can all materially affect the final estimate.
That is precisely what the accompanying GunFacts chart illustrates.
Defensive-gun-use estimates vary substantially among surveys because researchers use different definitions, questions, populations, and methodologies. GunFacts reports that the surveys it has compiled average just under two million defensive gun uses annually. The chart also displays an FBI UCR firearm-crime figure for comparison. Because the defensive-use estimates and crime statistics come from different methodologies and datasets, the comparison is best understood as an illustration of scale rather than a precise apples-to-apples statistical ratio. Source: GunFacts.info.
The chart is useful for another reason. It makes clear that the disagreement is not between researchers who find defensive gun use and researchers who find none. The disagreement is largely about how much defensive gun use occurs.
Surveying is particularly important because administrative crime databases cannot capture the full universe of defensive firearm uses. Many incidents never involve a shot. Some never generate a police report. A criminal may flee when the victim displays a firearm, announces that he is armed, or simply reaches for one. Nothing is stolen. Nobody is shot. Nobody goes to the hospital. The successful outcome may consist primarily of something that did not happen.
A homicide leaves a body, a death certificate, a police investigation, and usually records in multiple databases. A defensive encounter that causes an attacker to walk away may leave no comparable government record at all. The reasonable conclusion is not that every survey estimate is equally reliable or that we should automatically accept the largest number. We should not. The reasonable conclusion is that variation among estimates requires examining how each survey was designed and exactly what it measured, rather than treating disagreement over the precise number as evidence that the defensive benefit does not exist.
There is also an instructive history concerning the government’s own presentation of these numbers. For years, the CDC website discussed estimates of defensive firearm use drawn from the National Academies research. In 2022, the agency removed numerical estimates after gun-control advocates privately urged CDC officials to do so. Emails later obtained through public-records requests showed that one concern raised was that those figures were being cited in opposition to gun-control legislation.
In 2026, the CDC restored discussion of defensive-gun-use estimates to its website, again acknowledging that estimates vary substantially depending on methodology. Whatever one believes the precise number to be, that episode illustrates the larger problem: uncertainty about the magnitude of a firearm’s defensive benefit should be a reason to study the issue more carefully—not a reason to pretend the benefit does not exist.
Americans Tell Us Why They Own Guns
There is another clue that should not be ignored: gun owners themselves overwhelmingly identify protection as the principal utility of their firearms. Pew Research Center found that 72 percent of American gun owners say protection is a major reason they own a firearm. Eighty-one percent say owning a gun makes them feel safer. Roughly one-third of American adults personally own a firearm, while another significant portion live in a household where someone else does.
That does not prove that every owner’s perception of safety at any given time is objectively correct. But it tells us something important about the role firearms actually play in American life. For tens of millions of Americans, a firearm is not primarily a political symbol, a hunting implement, a recreational tool, or a collector’s object. It is a means of protection. And that protection has a characteristic that other forms of personal security cannot duplicate: it is immediately available to the person who needs it.
Police Are Essential. They Are Not Omnipresent.
Police officers perform an indispensable public function. But no police department can place an officer inside every home, beside every woman walking to her car, behind every convenience-store counter, or next to every person targeted by a violent ex-partner.
The police usually arrive because someone has already called them. That is not a criticism of law enforcement. It is a physical limitation on government protection. There is inevitably a period between the beginning of an attack and the arrival of professional help. Sometimes that interval is measured in minutes. Sometimes seconds determine the outcome.
During that interval, the victim is the first responder. A firearm changes the victim’s capabilities during those critical moments. That is especially significant because violent encounters are not contests among physically equal opponents. A firearm can give a smaller woman a means of resisting a larger male attacker. It can allow an elderly homeowner to defend himself against a younger intruder. It can reduce the significance of physical strength, age, disability, numbers, and other disparities that otherwise favor an aggressor. That equalizing function is part of the social utility of firearms, even when the gun is never fired.
What About the Armed Citizen Who Stops a Public Attack?
The same disagreement over definitions and classifications appears in the debate over armed citizens stopping active shooters. FBI reports recognize that civilians, along with law-enforcement and security personnel, have played roles in ending or attempting to end attacks.
John Lott’s Crime Prevention Research Center points out that the FBI substantially undercounts incidents stopped by armed citizens. CPRC’s database identifies hundreds of active-shooter incidents and says armed citizens stopped a substantial number of them, while the FBI’s narrower count credits armed citizens with stopping far fewer incidents. CPRC publishes its underlying case list so the disagreement can be examined case by case.
Those competing counts should not simply be collapsed into a single “true” percentage. Definitions differ. Classifications matter. Researchers disagree. But again, notice the asymmetry in the public debate. When a criminal uses a firearm to kill people, the event properly becomes part of the argument over the social costs of firearms. When an armed citizen stops that criminal, critics frequently debate whether the incident qualifies for inclusion in the defensive-use statistics at all. The methodological scrutiny should run both ways.
Gun Ownership and Violent Crime Are Not the Same Variable
The original version of this article argued against the proposition that the mere prevalence of guns somehow generates criminal intent. I would state the point more carefully today.
Firearms can make a violent criminal more dangerous. That proposition is hardly controversial. But the existence of a firearm does not explain why a person decides to rob, rape, assault, or murder someone. Criminal intent and access to a particular instrument are different variables. The trigger does not pull the finger.
Current crime data also caution against simplistic claims that widespread firearm ownership inevitably means continuously increasing violent crime. Gun ownership remains widespread, yet violent-crime and homicide rates can rise or fall substantially from year to year. That does not prove guns cause crime to decline. It establishes a more modest but still important point: the prevalence of privately owned firearms cannot, by itself, explain fluctuations in violent crime.
Crime is driven by people, places, incentives, social conditions, policing, prosecution, demographics, drug markets, gang behavior, and many other variables. Treating the object as the cause is tempting because objects can be regulated more easily than human behavior. But easy regulation is not necessarily effective regulation.
Social Utility Is Broader Than Defensive Gun Use
There is another problem with the way this debate is normally framed. A firearm’s social utility is not exhausted by the number of crimes it prevents.
Americans use firearms for hunting, competition, recreation, collecting, training, and the preservation of skills associated with responsible gun ownership. Those activities have value even though they do not show up in a public-health database.
We understand this principle everywhere else. Automobiles provide social utility even though they also kill people. Alcohol, swimming pools, motorcycles, prescription drugs, skiing, football, and countless other activities impose measurable risks while providing benefits that society values. We do not assess their utility by counting only fatalities. Yet firearms are frequently subjected to exactly that kind of analysis. The social value of an activity is not eliminated because misuse of the same instrument can cause harm.
There Is Also a Civic Function
The Second Amendment recognizes another form of utility that modern policy discussions rarely take seriously at all. The armed citizen historically had a civic function.
The militia was not conceived simply as another government agency staffed by professional soldiers. It drew upon ordinary citizens who were expected to possess arms and the competence to use them. That history matters even if most modern firearm owners never serve in an organized militia.
A population in which ordinary citizens possess firearms, understand them, train with them, and remain capable of using them reflects a different allocation of power than a society in which the state possesses an effective monopoly on arms. One does not have to predict imminent tyranny to understand the constitutional significance of that distinction. Fire extinguishers retain value even when the building is not burning. Constitutional safeguards can have utility precisely because circumstances requiring their ultimate use are rare.
The Policy Debate Has a Built-In Accounting Problem
None of this means gun ownership has no costs. It plainly does. The stronger argument is that both sides of the ledger have to be counted.
If a firearm is used in a homicide, we count the death. If a firearm is used in a suicide, we count the death. If a child is injured in an accidental discharge, we count the injury. We should.
But when the presence of a firearm causes a burglar to run away, there may be no government record. When it allows a woman to prevent an assault, there may be no injury to count. When an armed citizen causes a potential shooter to abandon an attack, the body count may be zero precisely because the gun worked. When a homeowner sleeps more securely because she has the means to protect herself, no statistic captures that benefit at all.
This does not mean every asserted defensive gun use should be accepted uncritically. It means a serious researcher should be just as interested in identifying benefits that administrative data fail to capture as costs that are easy to count. Otherwise, the methodology itself can predetermine the conclusion.
And Then There Is the Constitution
There is a final problem with treating gun policy as a conventional public-health cost-benefit exercise. The Constitution does not make the Second Amendment contingent on winning that exercise.
In District of Columbia v. Heller, Justice Scalia acknowledged the serious problem of handgun violence and the arguments supporting handgun prohibition. But the Court then said something that often disappears from today’s gun-policy debate:
“The enshrinement of constitutional rights necessarily takes certain policy choices off the table.”
The Court did not say that social consequences are irrelevant to policymakers. It said that an enumerated right limits what government may do in response to them.
Bruen made the point even more explicit. Courts are not supposed to decide Second Amendment cases by making contemporary judgments about the “costs and benefits of firearms restrictions.” The Second Amendment itself reflects a judgment made by the people who adopted it.
That distinction matters enormously. I believe the social benefits of lawful firearm ownership are substantial and routinely underestimated. But the constitutional right does not disappear if a future academic study claims otherwise.
Free speech is not protected because economists have proved that offensive speech produces a positive net social return. The Fourth Amendment does not depend on demonstrating that warrants maximize public welfare. And the Second Amendment does not survive only so long as gun owners can win an actuarial debate.
Count the Whole Ledger
The question of firearm policy deserves better than slogans from either side. There are genuine costs associated with firearms. There are genuine benefits. Some can be measured reasonably well. Others are much less visible in government administrative records. Some empirical questions will probably remain disputed for a long time.
But one methodological principle should not be controversial: If you are going to conduct a social cost-benefit analysis, you have to count both costs and benefits.
Do not count the criminal shooting and ignore the defensive display. Do not count the completed homicide and ignore the crime that never occurred. Do not count every misuse of a firearm while assuming every lawful possession has zero social value. And do not confuse disagreement over the precise magnitude of a benefit with evidence that the benefit does not exist.
Twelve years after I first wrote about the social utility of firearms, I would frame the issue somewhat differently. The evidence has become richer. Some of the arguments have become more complicated. And some claims deserve more caution than I gave them then.
But the fundamental point has held up remarkably well:
A society cannot intelligently decide what firearms cost while refusing to ask what they are worth.
C.D. “Chuck” Michel is the Founder and Senior Partner of Michel & Associates, P.C. His practice spans constitutional and civil-rights litigation, complex civil and criminal litigation, regulatory and administrative law, public-entity and municipal matters, environmental and land-use law, business and nonprofit governance, and firearms law.
Over more than three decades of practice, Michel has represented individuals, businesses, nonprofit organizations, trade associations, and public entities in state and federal courts and before administrative and regulatory agencies. His work has included constitutional challenges, commercial disputes, criminal and regulatory matters, environmental and land-use controversies, municipal and public-law issues, employment matters, and organizational governance. He has tried more than 40 jury trials and has handled writ and appellate proceedings in state and federal courts.
Court records reveal ATF lawyer William J. Ryan’s involvement in federal regulatory battles over pistol braces, forced reset triggers, and NFA gun trusts. AI-generated illustration.
Most gun owners couldn’t pick William J. Ryan out of a lineup. Nearly everything he has said about guns in public is buried in court filings. But if you owned a pistol brace in 2023, built an NFA collection through a trust, or bought a forced reset trigger, Ryan’s work touched you. Now he’s replacing Robert Leider as Acting Chief Counsel for the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
From Marine Lawyer to ATF’s Classification Chief
Ryan joined the ATF in April 2009 as a firearms and explosives attorney in Martinsburg, West Virginia, according to his own court declarations and a conference speaker bio. Before that, he was a Marine Corps judge advocate at Camp Pendleton. By early 2023, he was Acting Chief of the Firearms and Ammunition Technology Division (FATD). By that summer, he was signing filings as Chief.
Today his LinkedIn profile describes him as “Deputy Chief Counsel for a Federal Agency” who supervises 100 attorneys. The profile doesn’t name the agency. ATF is the obvious bet given his whole career, but I couldn’t confirm the agency or when he took the job, so treat that title as his own description, not an official one.
Gun Trusts and 41P
Gun owners first saw Ryan in 2015. At the NRA Firearms Law Seminar in Nashville on April 10, 2015, he spoke as an NFA Branch attorney about gun trusts.
The account comes from Pennsylvania gun-rights attorney Joshua Prince, who sues the ATF and titled his blog post “Shocking Statements/Concessions by ATF.” Keep that in mind. According to Prince, Ryan blamed much of the NFA backlog on trusts drafted by non-attorneys and fill-in-the-blank forms. Ryan said trust applications went from 45 in 2003 to 36,000 in 2012.
Prince wrote that Ryan said the ATF was “still sorting through the comments” on ATF-41P, the rule that changed how trusts and responsible persons were handled for NFA transfers. On a prohibited executor, Prince reported Ryan said the person “can’t possess it” and “it is on that person to know that.” Ryan also acknowledged that a trust counts as a “person” under the NFA but not under the Gun Control Act.
Sutherland Springs
Ryan’s most consequential testimony didn’t come in a gun-rights case. It came in Holcombe v. United States, the lawsuit over the 2017 Sutherland Springs church shooting.
On April 13, 2021, the government called Ryan to testify before Judge Xavier Rodriguez in the U.S. District Court for the Western District of Texas. Ryan told the court he had been appointed ATF’s liaison to the Department of Defense (DOD) Inspector General (IG) on the Devin Kelley case.
He also signed the ATF memo, using signature authority for the Associate Chief Counsel, that found Kelley was a prohibited person. The memo concluded Kelley was barred under 18 U.S.C. 922(g)(1) because of a felony-level court-martial conviction and under 922(g)(9) for a misdemeanor crime of domestic violence. It found he was not prohibited under (g)(4) or (g)(6).
The court later found the Air Force liable for failing to report Kelley to NICS.
Here’s the irony. Ryan was a government witness, but his testimony laid out the exact point the families needed: Kelley was prohibited and should have been in the system. The background check system didn’t fail because the law was weak. It failed because the government didn’t send in the records.
The Pistol Brace Rule
In 2023, Ryan put his name behind one of the most hated ATF rules in recent memory. On March 10, 2023, as Acting Chief of FATD, he filed a declaration in Britto v. ATF in the Northern District of Texas. He walked through the January 31, 2023 “stabilizing brace” rule, including its claim that most braced firearms are likely short-barreled rifles and its 120-day registration window.
He also addressed the pictures the ATF posted of common platforms and commercial models it considered SBRs. Ryan said those examples were informational, not final classifications, and that owners could request a classification letter for their own setup.
It didn’t end well for the ATF. On August 9, 2024, the Eighth Circuit held that the ATF’s brace test was likely arbitrary and capricious and reversed the denial of a preliminary injunction. The Fifth Circuit ruled against the agency too, and the rule was eventually abandoned.
The government posted a picture of your gun, called it a likely NFA item, and then its own classification chief told a court the picture wasn’t final. That’s the brace rule in one sentence.
Rare Breed Triggers
Ryan showed up again in the government’s case against Rare Breed Triggers over the FRT-15 in the Eastern District of New York. As Chief of FATD, he filed a declaration explaining how his division works. He said it had about 28 Firearms Enforcement Officers across five branches. He said those classifications determine whether an item falls under the GCA or NFA.
Rare Breed moved to exclude him. The company argued he was an undisclosed expert with no personal knowledge of the case. The Department of Justice called him a pure fact witness.
The court sided with DOJ. According to the government’s witness list, the motion to exclude Ryan was denied by minute entry on July 30, 2023. In May 2025, DOJ announced a settlement with Rare Breed.
The Award
Ryan also picked up an Attorney General’s Distinguished Service Award under Merrick Garland. DOJ listed him as “ATF Firearms & Ammunition Chief William J. Ryan,” alongside ATF’s regulatory affairs chief, rule writers, and the agency’s top lawyers. The release doesn’t say which rule earned the award.
What I Didn’t Find
AmmoLand News found no congressional testimony from Ryan and no Inspector General or GAO findings against him. A federal campaign finance search turned up no donations, though that search was limited and he may list a different employer or state. An X search found no posts naming him. I didn’t find any news coverage of him, including at AmmoLand.
The record does show a career ATF lawyer who sat at the center of the agency’s biggest fights over the last few years. He did it almost entirely out of sight. If he really is now one of the agency’s senior lawyers, gun owners should start paying attention to the name.
Mr. Crump is an NRA instructor and constitutional activist with more than 26 years of experience in networking and cybersecurity for major Fortune 100 companies. John has written about firearms, the Constitution, and cybersecurity, and has interviewed people from all walks of life. John lives in Northern Virginia with his wife and sons. Follow him on X at @right2bear, or at www.crumpy.com.
Three masked men reportedly threatened a Maryland resident with a handgun while he was sitting in his driveway on Halloween night. The resident was armed, fought back, and sent all three attackers fleeing. One attacker is dead, and two others are wounded.
Baltimore County Police are investigating an October 31 shooting in Cockeysville after an armed resident fired at three masked men who reportedly threatened him. iStock-901657484
Three masked men picked the wrong driveway on Halloween night when they allegedly threatened an armed Maryland resident, who drew his handgun and opened fire, killing one and wounding the other two.
The shooting occurred Saturday, October 31, around 10:40 p.m. in the 10000 block of Greenside Drive in Cockeysville, Maryland. According to Baltimore County Police, the resident was sitting in his driveway when three men wearing masks approached and threatened him. At least one of the men was armed with a handgun, but their intended victim wasn’t defenseless. The resident drew his own firearm and fired at the trio, sending all three running from the property.
The resident immediately called 911 to report the confrontation. When officers arrived, they searched the surrounding neighborhood and discovered one of the men dead a short distance from the home. Police identified the deceased as 20-year-old Amon Walker. The other two men, both adults, were later located after arriving at local hospitals seeking treatment for gunshot wounds.
Investigators also recovered a loaded handgun they believe belonged to the three men. Police have not identified the armed resident or released additional information about what led to the confrontation.
Possible Robbery Turns Deadly on Halloween Night
According to WBAL-TV, police described the suspects as wearing Halloween or novelty-style masks and indicated that the display of a firearm suggested a possible robbery. Investigators have not officially established a motive, but the circumstances paint a disturbing picture of three masked men confronting someone outside his own home late at night.
The shooting came just hours after families and children had filled the neighborhood for Halloween festivities. Neighbors told the Baltimore Banner that hundreds of trick-or-treaters had visited the street earlier that evening. Some residents initially mistook the sound of gunfire for fireworks before learning that a deadly confrontation had occurred nearby.
For the resident sitting in his driveway, however, there was nothing festive about the encounter. According to his account to police, he was suddenly confronted by three masked men, at least one carrying a handgun. Fortunately, he was armed and capable of defending himself against a potentially deadly threat.
Baltimore County Police said there was no continuing threat to the community. The department’s Homicide Unit is investigating the shooting, and authorities have not announced whether the two surviving men will face criminal charges.
Maryland’s Restrictive Gun Laws and the Right to Self-Defense
The confrontation also highlights why the right to keep and bear arms matters, even on one’s own property. Maryland has some of the nation’s most restrictive firearm laws, but Maryland Criminal Law § 4-203(b)(6) allows a person to carry a handgun on property they own, lease, or where they reside without obtaining a state handgun carry permit.
Maryland also generally imposes a duty to retreat before using deadly force outside the home when retreat can be accomplished safely. That distinction creates another legal concern for residents forced to defend themselves. However, the law does not demand that someone attempt an unsafe retreat in the face of an immediate threat.
The Second Amendment was never intended to protect Americans only when they are standing inside their living rooms. The right to armed self-defense extends beyond the threshold of one’s front door, and law-abiding citizens shouldn’t be forced to gamble with their lives when confronted by armed attackers.
In Cockeysville, the resident reportedly faced three masked men who threatened him with a handgun. Whatever additional details investigators uncover, the incident illustrates how quickly an ordinary evening at home can become a life-threatening encounter.
An Armed Citizen Refuses to Become a Victim
The facts reported so far tell a familiar story: a citizen going about his business is suddenly confronted by people allegedly threatening violence. This time, however, the intended victim had the means to fight back.
The resident wasn’t out looking for trouble. According to police, he was sitting in his own driveway when three masked men approached him. He had no advance warning and no opportunity to prepare for the confrontation, but he did have immediate access to a firearm.
The investigation remains ongoing, and police have not announced a final determination concerning the resident’s use of deadly force. Nevertheless, the incident serves as another powerful reminder of why armed self-defense is a fundamental right rather than a privilege granted by the government.
Criminals get to choose when and where they threaten innocent people. Armed citizens deserve the ability to defend themselves when that moment arrives.
Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.
From founding-era muskets to modern AR-15s, gun-control activists continue challenging the constitutional protection of commonly owned firearms. iStock-2191454516
Speaking at a town hall in Midland, Michigan, Abdul El-Sayed told the crowd:
“I’m gonna swear an oath to the Constitution. The Constitution has a Second Amendment in it, but the Second Amendment, just so we all are clear, even the most conservative folks, they hew to this idea called originalism, and originalism is the idea that you should interpret the Constitution in the context in which the Constitution was written.”
“When they promised the right to bear arms, they had muskets. So, yeah, everyone should have equal rights to a musket.”
The only thing that bothers me more than El-Sayed making the comment is a deep and abiding concern he actually might believe it. Considering El-Sayed is running for the U.S. Senate.
Abdul El-Sayed is very well-educated. He was born and received his primary education in Michigan. He graduated from the University of Michigan and was Rhodes Scholar, earning a doctorate from Oxford.
However, there he was in Midland, Michigan, exercising his First Amendment rights with a wireless microphone while claiming his Second Amendment rights were frozen in the 18th Century, protecting only a smooth-bore, muzzle-loading musket.
I wouldn’t expect El-Sayed to know about the Kalthoff Repeater, the Girandoni rifle, or the breech-loading Ferguson Rifle, but I have to assume he knew about the Kentucky Long Rifle.
The Second Amendment’s protection doesn’t stop there: It extends to swords, spears, lances, halberds, bows, all arms out of antiquity, as well as all the arms that appeared after December 15, 1791, the date the Bill of Rights was ratified.
I think it’s reasonable to assume El-Sayed has at least heard of District of Columbia v. Heller but he might want to Google Caetano v. Massachusetts when the Supreme Court ruled unanimously the Second Amendment protects weapons that weren’t in existence at the time of the Founding.
The Second Amendment is timeless, just like the First Amendment and the rest of the Bill of Rights.
One has to assume Abdul El-Sayed was being disingenuous, if not dishonest. Perhaps he is a full member of the League of Lobotomized Parrots, mindlessly regurgitating the pap excreted by the gun control movement.
El-Sayed says he’s “Gonna swear an oath to the Constitution.” Why? He obviously knows little to nothing about it, so his oath isn’t worth much.
Some memes are like cockroaches, impossible to eliminate.
Among these is the idiotic “weapon of war’ claim, which is based on the preposterous notion that the Constitution prohibits citizens from owning not only military-style but actual military surplus equipment, including firearms, artillery, and even fully functional tanks. Congress, with its taxing power, does regulate many of these things, but they can still be transferred. The exception is machine guns not registered by May 19, 1986. The Hughes Amendment to the Firearm Owners Protection Act of 1986 closed the door on the transfer of new automatic or selective-fire guns to private citizens.
Janet Carter is the managing director of Second Amendment Litigation for Everytown Law, Not long before the wannabe Senator shared his ignorance with an appreciative audience, Ms. Carter was interviewed on The Center Square, a newswire service covering federal and state governments. Greg Bishop, the host, asked Ms. Carter about pistol grips and other characteristics, saying that gun rights advocates call them cosmetic.
“It’s not cosmetic. There’s a reason why this is the weapon of choice for mass shooters. We’ve seen this, uh, that in the l–, the 10 highest casualty mass shootings over the last ten years, all of those shooters have used both an assault weapon and a large-capacity magazine and speaking to those features in particular, so, uh, the things that define an assault weapon under the statutes that are challenged in this case are a couple of things: First is the ability to accept a detachable magazine that allows a shooter to not only fire whatever rounds are in the magazine but also quickly to reload and keep shooting. Uh, the other features, things like a pistol grip, a forward grip, those are features of the gun that allow the shooter to re-aim and keep firing quickly and that’s why these are the features that were on these weapons when they were created for the military. They are designed to allow soldiers to fire quickly at a–, uh, enemy combatants. And these are not features that somebody needs for self-defense or for hunting.”
It appears Ms. Carter knows as much about self-defense and hunting as she does about firearms.
The first American semiautomatic rifle with a detachable magazine holding more than ten cartridges was developed for – and marketed to – hunters. It fired at the same rate as the AR-15, one shot per pull of the trigger. The year was 1907. The rifle was the Winchester Model 1907.
Fast-forward to 1942. The M1 Carbine was a semiautomatic rifle with a 15-round magazine. It was an actual weapon of war, designed and produced for the U.S. Military and issued to warfighters by the millions.
Late in the war, the Army fielded the M2 Carbine, a selective-fire version of the M1 Carbine.
The basic M2 didn’t have a pistol grip, or a forward grip, a flash hider, or a ‘thing that goes up’, but it did have a 30-round, detachable magazine, and a rate of fire comparable to the M16.
The M2 met all the functional requirements to be considered an assault rifle. Since it was semiautomatic only, the M1 Carbine did not meet those requirements. On the other hand, the M1 was still military grade and was used in combat in World War II, Korea, and Vietnam.
In the early 1960s, the U.S. government began dumping tens of thousands of surplus M1 Carbines onto the market. Prices were as low as $20 for NRA members. They could be bought at five-and-dime stores, such as F.W. Woolworth’s.
In 1968, Congress changed the National Firearms Act of 1934 because the M1’s barrel was less than 18 inches long. M1s have been used in seven mass shootings beginning with the University of Texas Tower incident in August 1966. With all that, the M1 Carbine was not among the guns proscribed by the 1994-2004 federal assault weapons ban.
Compare that to the AR-15. Virtually every gun-grabber claim is completely false, from Josh Sugarmann’s 1988 paper “Assault Weapons and Accessories in America” where he suggested using the term “assault weapon” to make the AR-15 and similar rifles appear more threatening, to the fantastic claims about lethality and rate of fire.
Of course, no gun control zealot worth their salt can mention “assault weapon” without breathlessly invoking mass shootings.
Americans own an estimated 30 million rifles like the AR-15, AK-47, SKS and others. Of that number, 92 have been used in mass shootings over the past 49 years.
Hardly seems like an existential threat.
Despite the mountain of data arrayed against bans, Ms. Carter says she’s “cautiously optimistic” because multiple federal district courts have upheld bans in the past. Guess she missed the memo about the Third Circuit Appeals Court declaring New Jersey’s bans on certain rifles and standard-capacity magazines were unconstitutional. This was an en banc ruling with the judges voting 10-5 to ban the bans.
The rulings supporting bans, like those from the Seventh and Ninth Judicial Circuits, used suspect reasoning, such as a resemblance to military weapons, to arrive at a politically palatable decision. Since the U.S.government has been selling surplus military firearms to citizens since 1903, that line of reasoning is unlikely to sway the Supreme Court.
Bill Cawthon first became a gun owner 55 years ago. He has been an active advocate for Americans’ civil liberties for more than a decade. He is the information director for the Second Amendment Society of Texas.
The Bureau of Alcohol, Tobacco, Firearms and Explosives’ (ATF’s) top lawyer, Robert Leider, has resigned as Chief Counsel.
Robert Leider resigned as ATF Chief Counsel on October 30, 2026, after helping oversee major firearms regulatory reforms. iStock-1371231628
ATF Director Robert Cekada said Leider tendered his resignation, and he has accepted it. Mr. Leider will return to the Antonin Scalia Law School at George Mason University as an Assistant Professor of Law. No other reasons were given for the resignation.
“Today, I accepted the resignation of ATF Chief Counsel Robert Leider,” Cekada wrote on X. “Robert has been a trusted advisor and has ably led ATF’s legal and policy work, strengthening the agency’s operations in countless ways. We are grateful for his service and wish him the very best as he returns to George Mason University, which is fortunate to have him back. Best of luck, Robert.”
The departure comes just weeks after Leider and Cekada sat side by side explaining the agency’s new National Firearms Act (NFA) guidance to gun owners.
Today, I accepted the resignation of ATF Chief Counsel Robert Leider. Robert has been a trusted advisor and has ably led ATF’s legal and policy work, strengthening the agency’s operations in countless ways. We are grateful for his service and wish him the very best as he returns to George Mason University, which is fortunate to have him back. Best of luck, Robert.. https://t.co/W1rVCWYo1Z
Mr. Leider’s appointment came in March 2025, shortly after Pam Bondi was confirmed as United States Attorney General on February 4 of the same year. He replaced rabid anti-gun lawyer Pamela Hicks, who was unceremoniously dismissed from the job. Bondi removed Hicks on February 20, 2025. Hicks confirmed the firing on LinkedIn, writing that she had been “served official notice from the Attorney General of the United States that I was being removed from my position as the Chief Counsel of ATF.” Hicks had served as Chief Counsel since 2021 under the Biden administration.
Before taking the position, Leider was a Second Amendment scholar who clerked for U.S. Supreme Court Justice Clarence Thomas and Seventh Circuit Judge Diane Sykes. At Scalia Law, he taught criminal law and torts. His scholarship focused on criminal law, criminal procedure, and constitutional law, with a particular focus on self-defense, the constitutional allocation of military power, and gun control. He published in the Florida Law Review, the Indiana Law Journal, and The Wall Street Journal, and he wrote “The Individual Right to Bear Arms for Common Defense.”
Leider also practiced at Arnold & Porter and Mayer Brown, and he holds a law degree from Yale and a Ph.D. in philosophy from Georgetown.
Just months before he took the job, Leider laid out his game plan in a December 2024 column for The Reload. He argued that gun-rights advocates would get more out of reforming the ATF than trying to abolish it.
“Instead of using their political capital to try and dismantle the ATF, gun advocates would likely see more success working within the system,” he wrote. “While federal firearms laws cannot be repealed by executive action, they still delegate significant power to the Attorney General (who subdelegates to ATF) on how the laws are implemented. The Trump Administration could shift many ATF policies in their favor.”
That is exactly what he set out to do.
A Wave of Rollbacks
During his time at the ATF, Leider supported the development and release of close to 40 proposed and final rules. These rules rolled back many regulations targeting American gun owners and streamlined regulation.
The changes started early. In April 2025, weeks after Leider arrived, the Department of Justice and ATF repealed the Biden-era “zero tolerance” Enhanced Regulatory Enforcement Policy, which had led to automatic license revocations for gun dealers over qualifying violations. The replacement policy, released in May 2025, requires a case-by-case review that considers a dealer’s intent, compliance history, and public-safety risk. Minor clerical errors can now get a warning instead of a death sentence for a small business. Cekada later said that he and Leider “rebuilt” the revocation process so that a revocation is not final until the director signs off, with Leider’s Office of Chief Counsel reviewing those cases.
In April 2026, the ATF rolled out its package of reforms.
Among them was a proposal to rescind the 2023 pistol stabilizing brace rule. Multiple federal courts had found that rule violated the Administrative Procedure Act (APA), and it had been enjoined, stayed, or vacated across numerous jurisdictions. The proposal would restore the regulatory definition of “rifle” to what it was before 2023. The agency said it “is a waste of resources to continue defending and trying to enforce the 2023 final rule.”
The package also proposed rescinding much of the Biden administration’s 2024 “engaged in the business” rule, which gun owners feared would turn private sellers into criminals. The ATF said it would keep only the definition Congress itself wrote into the Bipartisan Safer Communities Act. Many wished he had gone back to the rule as it was before Biden changed it. Because the ATF did not completely repeal the rule, the court battle still continues in Texas v. ATF.
Silencer Shop and the NFA
Leider also helped develop guidance on suppressors, short-barreled rifles (SBRs), short-barreled shotguns (SBSs), and Any Other Weapons (AOWs) after a ruling in Silencer Shop Foundation v. ATF.
The One Big Beautiful Bill (OBBB) Act, signed on July 4, 2025, cut the NFA’s $200 making-and-transfer tax on those items to $0, effective January 1, 2026. That left the NFA’s registration scheme standing without the tax it was built to enforce. On August 5, 2026, U.S. District Judge James Wesley Hendrix of the Northern District of Texas ruled that key registration and transfer provisions could no longer be justified under Congress’s taxing or commerce powers as applied to those untaxed items. He permanently barred enforcement against the plaintiffs, their members, and their customers. The Justice Department (DOJ) chose not to appeal.
Cekada and Leider said the ATF would treat all law-abiding Americans the same and would not enforce the enjoined provisions against anyone, whether or not they were technically covered by the injunction. They added that the guidance does not override state laws.
What Comes Next
Cekada, a career ATF agent who joined the bureau in 2005 after police work with the NYPD and in Plantation, Florida, became director in April 2026 after serving as deputy director since April 2025. He now has to replace the man who helped write much of his agenda.
That matters. The brace and “engaged in the business” repeals were published as proposed rules that have to clear notice and comment, and the fight over the Silencer Shop injunction is still playing out in court. Whoever takes over the Office of Chief Counsel will shape how those rules are finalized and defended.
The ATF has not named a successor or given a timeline for appointing one.
Mr. Crump is an NRA instructor and constitutional activist with more than 26 years of experience in networking and cybersecurity for major Fortune 100 companies. John has written about firearms, the Constitution, and cybersecurity, and has interviewed people from all walks of life. John lives in Northern Virginia with his wife and sons. Follow him on X at @right2bear, or at www.crumpy.com.