Commentary for Chullin 111:40

הא גופא קשיא אמרת

The defects enumerated by the Sages in the case of cattle equally apply [wherever possible] to birds; there is, however, this addition in the case of birds, namely: If the bone [of the skull] wa broken even though the membrane of the brain has not been pierced!' - He replied: 'The latter [defect] refers only to a water bird, for it has no membrane'.'

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