We are in total agreement Ron, the only thing I think that the ATF overlooks in their techical ignorance (and in many cases ignorance IS bliss) with regard to the Luger is the fact that ONLY the upper assembly is required to fire a cartridge and in reality is the equivalent of a complete barreled rifle action... to wit

a "firearm" by any definition... This is not true of the Ruger since it is not striker fired like the Luger.
I would NEVER want to discharge a 9mm round using only the upper assembly, but I have it on good authority that one of our near and dear Luger fraternity on the Lugerforum who specializes in refinishing Lugers (but we won't mention his name

) actually tried this because he wanted to know what it would feel like... I know we are all grateful that he still has all of his fingers...
best regards,
John S