The mechanical dispersion technology used in this study employs rotor-stator mixers that produce water-continuous high internal phase emulsions (HIPEs) with narrow drop size distributions and small drop sizes, even when the internal phase (oil) viscosity is quite high. Analysis of these HIPEs reveals trends that are consistent with formation by a capillary instability mechanism in which a shear deformation produces highly elongated drops that rupture to form uniform, small droplets. In the search for a predictive tool to aid in the manufacture and use of HIPEs, theology data for these shear-thinning HIPEs have been compared to data for models in the literature. Existing models do not correctly account for the effect of a high internal phase viscosity on the theological properties of the RIPE. Another shortcoming is failure to correctly address the shear-thinning exponent. Whereas internal phase viscosity does not seem to affect the shear-thinning exponent, the surfactant apparently plays an important role, possibly through its modification of the interfacial tension and continuous phase theology.