Gun Owners of America (GOA), a not-for-profit association of more than 200,000 Americans devoted to preserving their firearm rights, submits the following comments on President Clinton's November 6, 1998 Memorandum pertaining to the federal regulation of gun shows.

Let us say, at the outset, that it was a pleasant surprise to receive the Bureau of Alcohol, Tobacco and Firearms (BATF) request for the comments of GOA on the President's Memorandum.

It was a surprise because lack of constitutional authority has not prevented the BATF from being in operation as the result of an unconstitutional executive order. And lack of authority has not prevented this Administration, nor previous ones, from arrogation of police powers without constitutional warrant.

Lack of legality also was no bar when BATF agents were trained by the Combat Applications Group from Ft. Bragg prior to launching a murderous assault on the men, women and children of the Davidian religious group at Waco. And, of course, lack of authority did not stop the BATF from entrapping Randy Weaver, and then unleashing other federal police on his family with murderous results.

Accordingly, while there is absolutely no constitutional or legal justification for federal regulation of the private sales of firearms, GOA can think of no reason why this Administration will not do it anyway.

Therefore, you could surprise us, our members and the rest of the country by telling the President that we need to stop this insidious ongoing federal government assault on the American citizenry, and return to the rule of law.