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In page King Kong (1933 film):

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O'Brien and his special effects crew also devised a way to use rear projection in miniature sets. A tiny screen was built into the miniature onto which live-action footage would then be projected.[7] A fan was used to prevent the footage that was projected from melting or catching fire. This miniature rear projection was used in the scene where Kong is trying to grab Driscoll, who is hiding in a cave. The scene where Kong puts Ann at the top of a tree switched from a puppet in Kong's hand to projected footage of Ann sitting.[citation needed]