Tool
Black's Law Dictionary · Henry Campbell Black, M.A. · 1910
Black's Law Dictionary
The usual meaning of the word "tool" is "an instrument of manual operation ;" that is, an instrument to be used and managed by the hand instead of being moved and controlled by machinery.
Lovewell v. Westchester F. Ins. Co., 124 Mass. 420, 26 Am. Rep. 671.