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Is there something about Winchester's design that prevented the use of rimless rounds?

Marlin's don't seem to have an issue, but I don't recall any 94's chambered in rimless rounds. I remember hearing they redesigned the 358 into the 356 partly to that effect.

I believe it is strictly due to the extractor system. Do not think it’s inherent to the design.

And the Marlin brought out the 336ER in 356 Winchester anyway..

The Win 94 in the late 70s and early 80s began semi-rimmed usage in their 307 Win, 356 Win and included the 444 Marlin. The semi-rimmed cartridges head space off the rim even though the 307 and 356 are shouldered/bottleneck cartridges. The 308 Marlin Express is nothing more than a 307 Win, which is designed on 307 Win Brass.

Both 94 and 336/1895 chamberings shoot and extract rimless in the 450 Marlin, head spacing on the belt. Many Win 94 Big Bores have been rechambered in 458x2 American which is a rimless belted cartridge as well.

Obviously the Win 86, 71, 64, 94 all shoot rimmed. The 94 was always the smaller platform not allowing cartridge lengths greater than 2.6” for chambering. Another limiting factor to that is the large rimmed 45-70 and 348 Win. The loading gate on a 94 cannot accommodate that sized rim. It will however allow the .532” rimless 450 Marlin and the 458x2 American based on the 458 Win Mag brass or any cut down 375 H&H derivative.

Not sure what 336 Marlin chambering you are referring to when you are describing their merits with rimless cartridge use in lieu of the Win 94.

35 Remington is rimless and had been chambered in Marlins for decades

I have a feeling that two aspects took place regarding Win and their not chambering the 35 Rem. First, Win had several chamberings from 25-35 WCF to 33 WCF and obviously were in competition with Remington. Second, Remington introduced the 35 Rem in in their Model 8 autoloader, being rimless with a .460” rim. I’m sure Winchester never really found a rimless autoloader chambering attractive for their 94. Most if not all of Winchester’s 94 rimmed cartridges utilized a rim diameter of .500” or greater. Their smaller rims were on smaller length cartridges on their 92 platform such as a 25-20 WCF. My guess is they didn’t want to exercise extensive modification of the 94 to alter the lifters and overall feeding and chambering of the smaller rimless 35 Rem, especially for one oddball cartridge from their competitor. Marlin upgraded their bolt, extractor and system prior to 1950 and started to chamber the 35 Rem.

I will add that IMO the 444 Marlin is the best balanced tube feed lever gun chamber ever developed. With modern twist rate shooting 210 gr loads to 355 gr loads, it will handle any game in the field.

I used to have a Winchester 94 in 307 Win. For a while cases were very hard to come by and I loaded plinking loads with lead flat nosed bullets in 308 cases. They fed and ejected fine head spacing on the shoulder. Since 307 cases are made thicker and stronger than 308 cases, I kept velocities similar to 30-30 starting loads.

My guess is that Winchester was keeping things traditional in the tube fed lever action rifles even when boosting velocities with the 307 and 356 by retaining the rimmed case. It shouldn't have been a big problem to design a rimless round for the 94's.

I often wondered why Winchester never produced Model 94s in 35 REM

So that pretty much answers my question. There are design 'limitations' of the win 94 with varying effects on cartridge choice barring a notable redesign either for one caliber or many. Being smaller and lighter has its advantages afield.

Though I am not sure the cartridge redesigns in terms of the 'big bore' line was in retrospect wiser than additional modifications to the 94 action to accomodate a 308/358/45 70. I say that meaning I truly don't know, not because I have an educated opinion on the matter. Though perhaps that was also to avoid the dreaded pointed bullet in mag tube theory.

A sorta, kinda, maybe overview in respect of a few questions here. Winchester had its entire line of lever rimmed rounds from latter nineteenth century. They reflected the required diversity and in the 1894 genre a small ecosystem that worked well as proven over decades. The .35 Remington was part of a much narrower Remington series of four offerings: 25, 30, 32 and 35 Remington rimless rounds reflecting their smaller ecosystem offering arising in their Model 8 semi-auto and moving forward into their pump Model 14 rifles from about 1912 era. Savage had their's too in the Savage lineup. The point "proprietary". Remington. All three Firms were largely redundant with Savage perhaps the most forward thinking. Winchester sitting on market leadership as just to keep doing a good thing right. Remington was the 'also ran'. My belief and only that, Remington neither invested adequately in advertising budget nor promoted a dealer network. Not just less guns on dealer shelves but less ammo distribution. Savage was the engine that was trying harder and Remington was sitting on its laurels! Marlin was 'out there' too and wisely 'niched' with their really decent rifles as not attempting to do their own chamberings beyond perhaps some quite early production models. The adoption of Winchester chamberings was wise and a big advantage as the headache of dealer networks Remington had stumbled as trying to establish for ammo sales. The Marlin adoption was a wise anomalie.

All this isn't any kind of science, just my opinion over some decades at paying particular attention to rhe Remington Model 30 debacle as Winchester managing to sell twice as many Model 54 rifles in 11 years production than Remington Model 30 Remington managing to sell in nineteen years! So too their compliment of Semi-Auto and Pump guns. These were quality guns that didn't need any apologies, but for a manufacturer which never seemed to really 'get with the program'. The pumps especially did OK with botht the MOdel 14 evolving into the Model 141 in 1936 and the Model 8 into the Model 81 the same year. To me, the Models 14 & 141 were the Swiss Rolex watches of rifles. Great design but expensive to produce and the 'ruggedness' issue as competitive but not the 'toss around' of any of their lever competitors! I have a few of these pumps and truly appreciate them for the fine pieces of engineering and production skills they are! In 35 Remington a particular 'sweet spot'!

Rant ended. The 35 Rminton has lived on over a century as a fine chambering appreciated for what it is. Lacking "whizbang" appeal but good, solid and in various rifles. I even have a Stevens Lever an uncommon gun in .35 Remington from the Great War era!

Best!
John