That’s an incredibly biased reading of that. It’s the gun + 14” of shoe string attached to the trigger enabling automatic fire that’s the machine gun not the string on its own.
No, this 2004 letter specifies that the string with loops on its own, because it was designed to be used to modify a rifle to fire automatically, was a machinegun.
Three years later, in 2007 the ATF decided differently, "Upon further review, we have determined that the string by itself is not a machinegun..."
