To me a facinating point about Herr Theodor Scheimpflug and his rule is that (although I do not know this to be a fact) it must have serindipotous. The camera had long since been invented and had a bellows in order to be foldable and lighter. Was he the first to observe the inclined plane of sharp focus or were photographers aware of and exploiting the phenomina and Scheimpflug just set out to explain it? The Encyclopedia of Photography says nothing and I see nothing in Merklinger either. The answer probably can be found in the New York and London photography publications of the end of the 19th century.
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