The 1938 Guzzi, made by Earth Optical Company of Japan, resembles the ULCA with a view finder frame that clips down over the front and back. "Guzzi" is inscribed on the of the black film winder. The camera produced 18x18mm negatives on special paper backed rollfilm. It has a fixed focus lens with B (for bulb) and I (for instant) shutter speed settings. The Guzzi name was also used on 17.5mm HIT type film.

After the war, in 1948, the Top Camera Works resurrected the Guzzi and manufactured an almost identical camera but with a chrome plated wind winder with the word "Top" opposite the arrow.