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According to some experts (but not all), "traditional" figure heights are measured to eye level, since measuring to the top of the head is impractical for figures wearing headgear (as many military figures do).
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This is true. As a former freelance sculptor (wargaming terrain and accessories), I worked for several minis manufacturers, and every time when the scale question appeared, the manufacturer spoke about eye level. SO a 15mm scale figure measures 15 mm from feet to eyes most of the time
