which were made at various meetings held by the association, and the purposes for which meetings were called.

The interview had with the officers of the Blackwell & Panhandle sales office, of Spokane, Wash., is likewise instructive. The officers of this company maintained that the meetings at which prices and market conditions were discussed were purely informal gatherings and not meetings of the association; but they admitted that these meetings were called by the association.

The price activities of this group are of some years' duration. Bulletin No. 1 of the Western Red Cedarmen's Information Bureau was issued on November 19, 1915, and read as follows:

1. In figuring price on cedar stubs quote on per piece basis, dropping the fraction of a cent.

2. In quoting on cedar poles smaller than 6 inch 25's, treated, use the northern white cedar treating prices.

On January 19, 1916, this bureau issued a circular to its members, signed by Mr. W. M. Leavitt, in reference to a new price list. This circular also contained an outline of the reports which were to be obtained from the members and published by the bureau. The portion pertaining to prices reads as follows:

We inclose herewith new delivered price list on split cedar posts, also new code of ethics. The price list and the code of ethics both become effective February 5, 1916. It is understood that this price list will not be placed in the hands of your customers prior to February 5. Please check this price list over and if you have any corrections or any suggestions to make, please make them immediately by telephone.

On February 29, 1916, the James G. Noll Lumber Co. wrote Mr. Leavitt denying that it intended to join the association, but stating that it had been in the habit of obtaining as high prices as possible for its products and would continue this policy. It said:

* so even if we are not members you will find us in line with the rest of the

This letter was circularized by Mr. Leavitt. The James G. Noll Lumber Co. apparently sympathized with the association and desired to work with it. It wrote to Mr. Leavitt, complaining of prices which were being quoted by the Panhandle Lumber Co., an excerpt of which was contained in a letter written by Mr. Leavitt to the Panhandle Lumber Co. The James G. Noll Lumber Co.'s letter contained the following request:

We wish you would get after these people and see that they join the association or at least hold up prices.

The Blackwell & Panhandle Lumber Co. wrote Mr. Leavitt, addressing the letter to the Western Red Cedarmen's Information Bureau, on March 9, 1916, in which the following suggestion was made:

This, possibly, is all right from their viewpoint, but the only thing we see possible for us to do is simply for every member belonging to this information bureau to refuse to sell James G. Noll any posts. If the other members of the information bureau feel that they would like to tighten up on these people and not sell them any posts, excepting on a 25-cent margin, we would be pleased to know it, and assure you that we will do the same; in fact, that is the way we are selling to all wholesalers on a 25-cent margin.

A complete price list for posts was printed by the Shaw & Borden Co. for the association under the date April 1, 1916. The records of Shaw & Borden show that these lists were printed on the order of the E. T. Chapin Co., the proofs furnished this company, and the

company billed for the printing of the lists by invoice dated September 12, 1916. This invoice shows that these lists were mailed by the Shaw & Borden Co. to eight different companies.

An example of the informal manner in which prices were sometimes made is shown in a letter written by the Humbird Lumber Co. to the Blackwell-Panhandle Lumber Co. on April 8, 1916, as follows:

The question comes up whether it would be advisable to add $1 to the price of posts when shipped with lumber.

We would be glad to have your ideas in this matter, if you please.

The Blackwell-Panhandle Lumber Co. replied under date of April 10, 1916, as follows:

We have yours of the 8th with reference to price of posts in mixed cars with lumber. Will say that our price is list on posts or $1 per hundred higher than the carload price, and we have instructed our traveling men that we do not care for mixed cars of posts and lumber, even at this extra price.

On February 5, 1916, a code of ethics on split and round cedar posts was issued. One paragraph of this read:

Price: Quote $1 off new split post price list, dated February 5, 1916, and effective on that date.

On May 1, 1916, the bureau sent a circular letter to its members, inclosing a new "code of ethics," amended as of May 1, 1916. In this circular the bureau apologized for its delay in furnishing this information, and stated that it was due to the difficulties encountered by the committee appointed to compile the list. The circular stated:

We have been very slow in getting this round-post list out, as the committee that was appointed to work on it had considerable trouble in getting together on account of one or more of the members being out of the city most of the time.

This price list was a mimeographed list.

On May 2, 1916, the bureau again circularized the trade in reference to this price list, pointing out an error which had been made by the stenographer in compiling the list.

A new price list for posts was attached to a circular issued by the bureau to its members on September 21, 1916. The circular read:

We inclose herewith one copy of printed round-post list. The prices contained in this list are exactly the same as those in the list that you now have, excepting the price on the 7-inch 10-foot posts has been corrected on a 49-cent rate to $84. Additional copies of this list can be secured from this office at 5 cents per copy.

A new pole price list was inclosed in a circular sent by the bureau to its members under date of November 11, 1916. The circular discussed in detail the time when this list was to be effective, and the change in prices which had been made. It read as follows:

Inclosed herewith you will find price lists showing prices we are quoting on woods run and class poles. Also full selling instructions which are attached to each price list. These price lists and selling instructions are complete and cancel all previous price lists and selling instructions. In addition to the selling instructions, we also inclose one copy of supplement No. 1 to the selling instructions and a notice of advance in prices on 5-inch and 6-inch 25's in Canada.

These price lists should be delivered to you the morning of November 15 and we are putting them into effect Wednesday morning, November 15, 1916. We are checkir 3 up all of our old quotations and canceling or correcting all that do not conform to the inclosed price lists.

We are accepting at old prices orders which were put in the mail on the 14th instant. The principal changes in the woods run price list are as follows:

6-inch 30-foot, price increased 40 cents; weight lowered 25 pounds.

8-inch 30-foot, weight increased 50 pounds.

7-inch 35-foot, price increased 25 cents, weight increased 50 pounds.

8-inch 35-foot, weight increased 25 pounds.

7-inch 40-foot, weight increased 25 pounds.

6-inch 40-foot, price has been changed so that it is just 25 cents less than 7-inch 40-foot.

The prices on practically all class poles have been changed more or less.
Trusting that you will receive these price lists promptly on the 15th, we are.

On November 14, 1916, Mr. Leavitt sent a telegram to the eastern dealers regarding this same price list, which read as follows:

You should receive Wednesday morning by Great Northern Express price lists that become effective Wednesday, the 15th. Cancel or correct all old quotations. If price lists are not received by noon, advise me by wire.

Another advance on posts was made on November 21, 1916. On that date Mr. Leavitt issued a circular, on the letterhead of the Western Lumber & Pole Co., which read as follows:

We are to-day advancing our price on split cedar posts to full list. This is an advance of 1 cent over the prices we are quoting at the present time. We are quoting the same prices on round posts that we have been quoting in the past.

The manner in which meetings of these groups were called is shown by a circular issued November 13, 1916, on the letterhead of the Western Red Cedarmen's Information Bureau, which was a call for a meeting of the cedar-post men to be held on November 21 at the Hotel Davenport, in Spokane. The circular stated:

This meeting is called at the request of several of the members who believe that the low stocks and general condition of the post industry warrant very careful consideration of the present market. They seem to think that the market is stronger than it has been for some time. This is a matter in which everyone is vitally interested and I trust you will have a representative at this meeting.

On November 21, 1916, Mr. Leavitt issued a circular, with which was inclosed a copy of "Selling Instructions." This circular stated: You will note * * that the State of California has been added to the open territory and we are quoting full list prices instead of $1 off.

*

Another call for a meeting of post manufacturers, to be held at the Davenport Hotel, Spokane, Wash., on December 12, was issued by Mr. Leavitt on the letterhead of the Western Red Cedarmen's Information Bureau. This circular stated:

This meeting is called in accordance with a resolution passed at the last meeting and we trust that every member of the organization will have a representative at this meeting.

The circular continued with a request for each member to furnish a list of all posts on hand and a statement of shipments made during the preceding month. It further stated:

We would also like to call your attention to the fact that we were instructed to get prices on new post lists and we will expect to have you come to the meeting prepared to state about how many of these lists you could use and what form you wish them gotten out in.

On December 10, 1916, the Blackwell & Panhandle sales office (which is the selling organization for two or more companies) acknowledged the receipt of this circular and promised to have a representative at the meeting. At this meeting it was decided to issue a new standard list, which was to be compiled by the bureau. This is shown by a circular issued by Mr. Leavitt, on the letterhead of Western Red Cedarmen's Information Bureau, dated December 30, 1916, which reads as follows:

At the last post meeting which was held in Spokane it was understood that a standard list would be gotten out, and this office was instructed to get prices from the various printing houses. We have not been able to get sufficient information from the different dealers to enable us to get these prices.

After taking this matter up with the different dealers, it was decided that it would be best to hold another meeting Tuesday, January 9, at which time we could decide upon a standard list and the best method of getting it out.

A number of other matters will come up at this meeting and we trust you will arrange to have a representative present. Kindly advise us if you will have a representative at this meeting, and if not, what your position will be relative to getting out price lists and how many you will want, if any.

The above-quoted circular announced a meeting was to be called on January 9, 1917, for the purpose of deciding upon a standard price list for posts. The commission was unable to obtain a copy of this price list if one was issued. However, on January 29, 1917, the Weyerhaeuser Sales Co., St. Paul, Minn., issued a bulletin to some of its salesmen, called Bulletin No. 141, in reference to the sale of posts. It contained this statement:

We are now supplied with split and round post price lists; let us know if you need any.

Bulletin No. 147, without date, was issued by the Weyerhaeuser Sales Co., and contained the following statement:

Attached please find new split-post list as issued by Humbird Lumber Co. under date of February 1, 1917, showing advance of $2 per hundred, with a discount of $2 per hundred until further notice. Same effective at once.

The Humbird Lumber Co. was not a member of the Lifetime Post Association in the spring of 1920. It is not known if this company was a member in 1917. If it was not, it probably worked in conjunction with the association. The files of the Shaw & Borden Co. show that price lists when printed were always sent to the Humbird Lumber Co.

Another advance on posts was made by the Humbird Lumber Co. the 1st of April, 1917, as shown by a circular issued by the Weyerhaeuser Sales Co. to its salesmen, dated April 2. The extent to which this same advance was made by competitors of the Humbird Lumber Co. is not shown.

About this time a new pole price list was issued. Mr. Leavitt, on May 31, 1917, issued a circular to members of the pole association upon the letterhead of the Western Lumber & Pole Co., which read as follows:

We attach hereto list showing advances on woods run and class poles, which we are putting into effect June 2. We are adding the figures shown in column headed 'Advance" to the f. o. b. and delivered price lists dated December 20, 1916.

Another circular, upon the stationery of the Western Lumber & Pole Co., was issued on June 6, and read as follows:

Under date of June 5 we sent you a supply of the new delivered price lists on poles effective June 2, 1917. With this supply of delivered price lists we mailed you one copy ci f. o. b. prices which in some way slipped through without being checked, and we have found several errors in same. We will ask that you kindly return same at your earliest convenience, and oblige.

The Weyerhaeuser Sales Co. on June 5, 1917, issued a circular to its salesmen announcing advances on poles made by the Humbird Lumber Co. The prices mentioned by the Western Lumber & Pole Co. have not been checked with those enumerated in the Weyerhaeuser Sales Co.'s bulletin, but the coincident advance in prices is significant.

A meeting in Minneapolis was held in August, 1917. On August 15 Mr. Leavitt sent the following telegram to Mr. E. L. Clark, president of the Valentine Clark Co., Minneapolis, Minn., who was a member of the Western Red Cedar Association:

Will leave here Friday morning, Great Northern. Eight in party.

In his interview with the representative of the Federal Trade Commission, Mr. Leavitt stated that, while prices undoubtedly were discussed at this meeting, he did not believe that the primary object of the meeting was to discuss prices.

On September 4, 1917, Mr. Leavitt issued a circular, on the stationery of the Western Lumber & Pole Co., with which was inclosed a "corrected f. o. b. price list, which we are using instead of the one dated June 2, 1917.' An explanation was made of the portion of the price list referring to "cost," and the statement made that the cost figures "were originally submitted by Mr. C. P. Lindsley and are now being used as more nearly approximating the correct cost than the old cost price list." (The purpose of these cost figures is explained later in this report.)

A circular was issued by Mr. Leavitt on the stationery of the Western Lumber & Pole Co. on November 16, 1917, pertaining to a new price list on piling, which read as follows:

We are sending you under separate cover new delivered price lists and selling instructions on piling, which we are using in connection with our quotations.

Another circular was issued in the same day in reference to poles This circular read:

We are inclosing herewith copy of our f. o. b. price list on poles showing estimated cost. Also f. o. b. price list on poles with estimated cost not shown. Additional copies f. o. b. price list on poles with estimated cost not shown may be secured from this office upon request.

A third circular was issued on this same day with reference to "selling instructions," commission to be paid sales agents, etc.

On November 21, 1917, Mr. Leavitt wrote to Page & Hill Co., Minneapolis, Minn., that he expected to be in Minneapolis the first part of December, and suggested that if there was a meeting of the manufacturers of the section at that time he would like to attend. Mr. Leavitt, in his interview with the commission's representative, stated that his attendance at this meeting was not official; that he did not remember if prices were discussed, although he undoubtedly gave his views on general market conditions.

Another meeting of the post men was held in Spokane, Wash., on December 14, 1917. This meeting was called by circular dated December 8, 1917, issued on the stationery of the Western Red Cedarmen's Information Bureau.

A new post price list, dated December 14, 1917, was printed and exhaustively distributed by the printing firm, Shaw & Borden Co. On February 2, 1918, the Weyerhaeuser Sales Co. issued a bulletin. to its salesmen in reference to the "new combination list for round and split cedar posts, which cancels and supersedes the previous lists." The changes made in this list were pointed out, but the date of the list was not specified.

Another price list for posts, under date of March 22, 1918, was printed and distributed by Shaw & Borden Co. to all the members of the association.