Ben Doyle mentioned that the Plane can be "Curved" in his TGM 24 Components Video.
Ben may have been referring to the various Plane Shifts, e.g., from Elbow to Turned Shoulder and back again. But since those Shifts tend to be more vertical, i.e., directly from one to another, maybe not.
Then again, he may have been referring to the Turning Shoulder Plane (10-6-D).
I don't remember a reference to 'curved' planes in the various editions of TGM. There may well be, but I can't recall it.
Haven't watched his video in a while, but I'm sure I will again. No doubt Ben had something specific in mind. I will pay special attention next time.
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