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The Mitsubishi Ki-39 was a design for a twin-engined heavy fighter. It was produced in response to a Japanese Army specification of 1937 that called for a twin engined heavy fighter and that was issued to Nakajima (Ki-37), Kawasaki (Ki-38) and Mitsubishi (Ki-39). Mitsubishi began work on the normal Ki-39 and on a longer range aircraft, with the designation Ki-40. Neither of these projects reached production, and during 1937 Mitsubishi and Nakajima were both allowed to drop their projects.
Mitsubishi's effort wasn't wasted. On 12 December 1937 the Army issued a new specification for a long range reconnaissance aircraft. Much of the work that had been carried out on the Ki-39 and Ki-40 was used to help with the development of the resulting Mitsubishi Ki-46 Dinah, one of the best reconnaissance aircraft of the Second World War.