Bill: You are correct in your observation regarding serial numbers; and also correct that there are no shipping records for guns above 219750, as these records have disappeared. As a result, requesting a Cody letter will be fruitless. If you have read Brophy's original work, the time frame when your gun was originally manufactured was a transitional period; Hunter Arms was in bankruptcy and he/we speculated that is the reason why some records from that era may be incomplete. One of our directors, Bill Winter, also has a Spcialty Grade with a serial number very near yours that is not in the recap.