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1938 Goudey began numbering cards at #241, where the 1933 set left off. The card fronts feature a players head with the body of a cartoon drawing. There are a total of 48 cards in the set, 24 players with 2 cards each. The backs of these cards have player statistical and biographical information along with the Big League Chewing Gum ad.

Cards #241-264 feature plain backgrounds on the fronts. Cards #265-288 contain the same design and photo but include small drawings and comments in the background.