The founder of a conservative political watchdog group is the first in the nation to file a lawsuit against the federal government over President Obama’s recent executive actions on gun control.

Claiming the president cannot redefine laws enacted by Congress, Judicial Watch founder Larry Klayman filed a lawsuit in federal district court on Monday naming Obama, US Attorney General Loretta Lynch and Deputy Director of the Department of Justice, Thomas E. Brandon, as defendants.

“The Defendants’ rewriting of laws burdening and abridging the fundamental rights of the Plaintiff and other US citizens under the Second Amendment by the President and his executive branch is unconstitutional,” the complaint filed in the U.S. District Court for the Southern District of Florida states.

“These actions are unconstitutional abuses of the President’s and executive branch’s role in our nation’s constitutional architecture and exceed the powers of the President as set forth in the U.S. Constitution.”

The complaint argues Obama’s executive actions attempt to redefine ATF enforcement activities and policies, including “who is a ‘dealer’ in firearms ‘engaged in the business of selling firearms,’” according to a press release regarding the lawsuit.

“The change of interpretation now sweeps up persons who do not seek to earn a livelihood or make a profit, who buy or sell as few as one or two guns a year,” the press release says. “Worse, the new rules are so vague and subjective that Klayman challenges them as ‘void for vagueness.’ Being treated as a dealer now creates the obligation to conduct background checks for those sales.”

The lawsuit is in response to the January 4 announcement from President Obama where he stated he would unilaterally implement further infringements on the Second Amendment.

Check out the rest of Larry Klayman’s complaint below:

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