STURM, RUGER & Company, Inc.
Lacey Place
Southport, CT 06490
Telephone 203-259-7843
Fax 203-259-6688

Memorandum

TO:        All Authorized Sturm, Ruger Distributors

CC:        All Sturm, Ruger Sales Representatives

From:    Robert Thompson, Sales Manager

Date:      March 5, 2002

Re:        Certification of Revolvers for Sale in Massachusetts

Sturm, Ruger is pleased to announce that, after much effort, it now has certified a variety of Ruger revolvers for sale in Massachusetts. After reviewing the Massachusetts Attorney General's Regulations and Enforcement Notices, the Massachusetts Gun Control Act of 1998, etc., Sturm, Ruger has prepared a list of Ruger revolvers that can be sold legally in Massachusetts. A list of these handguns is attached hereto. Sturm, Ruger notified the Massachusetts Attorney General that it has certified the revolvers listed on the attachment as legally available for sale in Massachusetts.

Please note that the attached list contains everything that currently is being certified by Sturm, Ruger. More to the point, you will notice that there are firearms that are listed on the roster published by the Massachusetts Executive Office of Public Safety ('EOPS') that are not being certified by Sturm, Ruger for sale in Massachusetts.

As noted in a recent memo to all of you from our legal department, this roster is only part of the equation. In order to legally be available for sale in Massachusetts, a revolver and the 'purveyor' of that revolver must also satisfy all applicable provisions of the Gun Control Act and AG Regulations. Nonetheless, now that the roster has been published, it is possible to compare it with the AG Regulations and finally deduce which revolvers legally can be sold in Massachusetts. That is how we compiled the attached list.

You will notice that all Ruger pistols are absent from the attached list. Rest assured that Sturm, Ruger has long been attempting, without success, to obtain clarification from AG's office that at least our Mark II .22 caliber Target Model Pistols can be certified for sale in Massachusetts. If this occurs, you will be notified accordingly.

You still need to be mindful of other aspects of the AG Regulations that may apply. In order to assist in this endeavor, I have attached two memoranda. One memorandum related to the warning requirement codified at 940 CMR 16 06(1). The other memorandum provides accuracy data for Ruger revolvers with a barrel length of less than three inches. Note the Massachusetts Gun Control Act and AG Regulations mandate this latter requirement.

Obviously, you need to review the AG regulations yourselves and verify that you also comply with them. The AG regulations can be found in the Code of Massachusetts Regulations beginning at 940 CMR 16.00. If you have any questions, I suggest you contact the Massachusetts Attorney General Directly.

Thank you for your cooperation and patience in this long-delayed process.

List of Sturm, Ruger Firearms Certified
For sale in Massachusetts as of March 5, 2002

To Comply with these laws and regulations, and to assist you in doing so, Sturm, Ruger provides the following information:

The only products Sturm , Ruger manufactures that have barrel lengths of less then three inches are certain models of our Ruger SP101 Double action revolver. The Sturm, Ruger catalog numbers for these revolvers are KSP-821X, KSP-321X, and KSP-321XL. For these models, the overall average five-round group diameter accuracy (using standard ammunition) at 7 yards, 14 yards and 21 yards is 2.4". 3.5" and 5.8" respectively. These results were obtained from accuracy testing done by Scott, McDougal & Associates, and independent testing laboratory approved by Massachusetts.

Reprinted by permission