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ORIGINAL PETITION. 39
manufacturers. Independent exchanges are cut off from handling the film of the ten Patents Company licensees and independent exhibitors and theater owners can not obtain for exhibition in their theaters the pictures of the Patents Company licensees.
In conclusion, all the unlawful restraints and conditions contained in the license agreements and described in this petition defendants to-day are observing and enforcing, and will continue to observe and enforce unless restrained by this honorable court.
XIII.
JURISDICTION.
Petitioner avers that the combination and conspiracy to restrain interstate and foreign commerce and motion-picture films, machines, and apparatus relating to the motion-picture art still exists; that the defendants are carrying out and engaging in the same within the State of Pennsylvania within the Eastern District of said State, and that many of the things herein complained of have been committed in whole and others in part within the said State and district and are now being committed therein; that the defendant Lubin Manufacturing Company is located at and doing business within said State and district.
XIV.
PRAYER.
Wherefore petitioner prays:
1. That the combination hereinbefore described, in and of itself, as well as each and all of the elements composing it, whether corporate or individual, whether considered collectively or separately, be decreed to be in restraint of interstate and foreign trade and an attempt to monopolize and a monopolization thereof within the first and second sections of the act of Congress of July 2, 1890, entitled ^^An act to
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