In very old C dialects, before there was any standardization, when the FILE type was invented, and before the typedef existed, this name was a macro:
#define FILE struct _iobuf
The agreement was for macros to be named in all capital letters.
http://minnie.tuhs.org/cgi-bin/utree.pl?file=V7/usr/include/stdio.h
(the macros that were in lowercase were just optimized versions of the functions - many of them also existed as valid functions)
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