This variation is the rarest of all military P38 pistols and the first Walther pistol to use the "ac" code, with a total production of about 2,700. This variation is marked "P.38 ac" and the serial number on the left side of the slide, absent of any date. The left side of the frame is marked with the serial number followed by an "eagle / 359" proof. The left front of the trigger guard is marked "ac". The right side of the slide toward the rear is marked with the German firing proof flanked by "eagle / 359" proof marks. The locking block is marked "495", the "9" is double struck and may have been an "8", and the sides have the correct proof marks. Most small parts are marked with the "eagle / 359" proof mark. A trigger stop has been installed which comes through the bottom rear of the trigger guard. Fixed sights, blue "P38" marked magazine stamped "485" on the bottom of the toe and fitted with two piece black Bakelite grips with a lanyard ring on the left side heel.

Fine with approximately 30% original finish on the frame with the balance refinished. The slide sides has a mottled grayish patina with some scattered pin prick type pitting and there is a small amount of pin prick type pitting on the forward portion of the barrel which is a mix of blue and brown patina. The front strap has a smooth gray patina, while the trigger guard has a smooth blue brown patina. The grips are excellent with a few minor dings and scratches. The markings are clear. The action is excellent. One will search for a long time to find another one of these extremely rare "ac" no date P38s.