If your primary collecting focus is in collecting CM horses or hand-painted resins, you can say with some justification that every horse on your shelves is a one-of-a-kind model. Even if they're all painted by the same artist and in similar colours, it's a matter of fact that each hand-painted horse will be different from every other one.
Theoretically, the same could be said for any hand-painted factory-produced models. In fact, some OF collectors love to acquire all the subtle variations in paint shades and markings that they can find in their favourite molds. But factories are not really trying to create OOAK horses. They're trying for consistency. The fact that it's impossible to achieve just shows how many different uncontrollable factors go into the creation of a model horse.
Which is not to say that you cannot get true OOAK OF horses. Both Beswick and North Light used to offer customized colours to those who requested them. The collector would still be getting a horse done in the company's signature style and with its signature paints, but the colourway could be anything the collector fancied, from a portrait of her own horse to a representation of the horse she would love to own. Breyer and Stone also offer this service today, though at a considerable cost.
Additionally, Breyer, Stone, and Lakeshore offer Test pieces for sale from time to time, and Stone has not only the Design-a-Horse (DAH) program but also offers OOAK models to collectors as an actual section of their website offerings.
My one and only OOAK? (Photo from the Stone Company website)
Oddly, while I find myself reluctant to accept a Test piece as a OOAK, I sometimes wonder whether some of the Stone Design-a-Horse models might actually be OOAKs in disguise. A Test, after all, may be part of a Test Run (involving more than one model) or it may be such a successful test that it bears no visible difference from the models produced in the regular run.
With Design-a-Horse -- who knows? There are enough choices of colours, patterns, bodies, and markings on offer each month that it seems to me highly probable that the horse one person designs will be unlike any horse designed by anyone else. However, there's nothing stopping Stone from liking a certain DAH piece so much that they decide to use the design in a regular run. The problem in both cases is that you'll never know.
My skepticism about the likelihood of any one horse being truly OOAK stems primarily from my dealings with Stone. I currently own one Stone Test piece, four DAH horses, and one OOAK. The Test, for the Midwest Horse Fair Weanling "Foolish Pride," looks for all the world like all the Weanlings from the actual run I have ever seen -- definitely not OOAK. My four DAHs -- a grulla English Pony, a chocolate palomino Thoroughbred, a sorrel Mustang, and a silver bay Chips Warmblood -- all have no twins on the Stone Horse Reference database, so as far as I can tell they are all OOAK, at least for now. And my only OOAK, a kind of champagne appaloosa Ideal Stock Horse released under the name "Wheatena," is OOAK -- so far. Since she was marketed as OOAK by Stone I would not expect them to ever create another one on their own, but who knows if it might not be possible, some time in the future, for someone to design a mighty similar horse?
So how do you really know when you have a OOAK on your shelves? Well, if the horse is actually marketed as OOAK, you can be pretty confident that it is just that -- and probably (but not certainly) will remain so. Beyond that ... well, you pays your money and you takes your chances, and for some the risk definitely pales in significance compared to the reward.
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