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How did you identify the "late action", by pin placement in side of frame?
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Yes. Seems like the new style action with the seperate firing pins appeared along with the FE-Grade Trap Gun in 1906.
New style cut-away and parts diagram --
Older style cut-away and parts diagram --
I had barely posted my comment about not seeing 10-gauges on the new style action that one of my interlocutors sent me pictures of his 1907 vintage CEO-Grade 10-gauge!!!