If you're measuring hFE for a germanium transistor, you will get not only the gain but also the current leakage of the transistor, leading to an artificially high result. Most Ge trannies have significant leakage, so this error can be considerable. Small Bear corrects for the leakage in the value they report. Here's an article on how this correction is determined:
http://www.geofex.com/article_folders/ffselect.htmAnd as Nick said, the hFE measurement of Ge transistors is STRONGLY temperature dependent, so I recommend handling them with pliers or forceps.
Silicon transistors don't have these current leakage or heat sesnitivity problems, so if you're measuring one of those, you can ignore the first part of this post!
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