I don't believe I have seen this variant before. The seller incorrectly attributes this to Beistle. It was made in 1935 in Germany. I have seen the basic skull and crossbones diecut with three different hats before seeing this one, so there were at least 4 designs, but more likely a total of 6 designs. If the damage wasn't so obvious, it would be a candidate for acquisition.
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Mark B. Ledenbach's vintage Halloween collectibles blog.