http://www.georgiapacking.org/docs/akins/Complaint_with_exhibits.pdf Cliffs: Count 1 Regulatory Takings 40. By ruling that the Akins Accelerator is a machine gun, after first ruling that it was not, and by applying the provisions of 18 U.S.C. § 922(o) retroactively to Akins Group, Inc. (who produced and distributed Akins Accelerators at a time when they were not considered to be machine guns), and to Plaintiff Akins personally, Defendant has taken Plaintiff s private property for public use without just compensation, in violation of the Fifth Amendment to the Constitution of the United States. Count 2 Physical Takings 41. By confiscating the spring from Plaintiff s Akins Accelerators, Defendant has taken Plaintiff s private property for public use without just compensation, in violation of the Fifth Amendment to the Constitution of the United States. Count 3 Violation of Due Process 42. By determining that Plaintiff s property was a machine gun without a hearing, Defendant failed to provide Plaintiffs with the due process of law. 43. In classifying the Akins Accelerator as a machine gun, Defendant acted arbitrarily, capriciously, and without factual basis. Demand for Relief Plaintiffs demand the following relief: 1. Damages to compensate Plaintiff for the taking of his property. 2. A declaration that the Akins Accelerator is not a machine gun. 3. An injunction prohibiting Defendant from treating the Akins Accelerator as a machine gun for any purpose. 4. Any other relief the Court deems proper.