I agree .. it does not state "completely disassemble" ... but you have to decide ... a jury trial or trial by judge ... they will claim that you did not dissassemble the upper from the lower because the front pin is still on... its really partially disassembled ... I guess a jury trial with a motion to acquit to start out with ...To clarify, as I understand it, this device meets the requirement for both the old definition and the proposed definition.
But the law says "(4) "Detachable magazine" means an ammunition feeding device
that can be removed without disassembling the firearm action;"
And the firearm action includes the parts of the upper and lower ...
(3) "Action of the weapon" means the part of the firearm that loads,
fires and ejects a cartridge, which part includes, but is not limited to,
the upper and lower receiver, charging handle, forward assist,
magazine release and shell deflector;
Disassembling, I think, means "in the process of being disassembled" .. and in that respect you are in the process of disassembling the lower from the upper.
Indeed, the top loading AR's don't require a complete disassembly of the action ...