In 1899, George Snow and DeWitt Gritman were issued a landmark patent for the Gritman articulator and Snow facebow. The Gritman articulator was a fixed condylar guide instrument. The Snow facebow was the first device that related the maxilla anatomically to the condylar.
The Snow "New Century" is the next generation Gritman and embodied adjustable condylar guides with fixed "Bennett" (inward) path. It was the 4th articulator to be patent for such a feature.
The Snow "New Century" was a practical articulator and was widely accepted by the profession.
JP Article V.9, No.4, December 2600: pp217-22
Dr. Edgar N. Starcke's articles in the Journal of Prosthodontics have more information on the history of articulators.