Ninth Circuit Judge Van Dyke created a YouTube video to accompany his dissenting opinion in Duncan v. Bonta. In the video, Judge Van Dyke demonstrates with various gun parts how California's argument, accepted by the majority, that magazines holding over ten rounds are mere accessories and not protected arms under the Second Amendment, is flawed. He argues that the same logic could be used to classify almost any part of a firearm as an unprotected accessory, including essential components and even the firearm's operating mechanism, due to the possibility of replacement or modification. Judge Van Dyke contends this viewpoint reflects a fundamental misunderstanding of firearms and their functionality, asserting that a complete firearm, including standard magazines, should be considered an arm.