United States of America v. Motion Picture Patents Company and others (1914)

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4 280 et seq.). In the Anthracite Coal case, defendants separately and individually had entered into a number of contracts with interstate carriers. Each contract had been entered into by only one of the defendants, and the contracts had been executed at various times. However, owing to the fact that each contract formed part of a concerted plan to secure control of coal and suppress competition, the court condemned each of the contracts. The court said that it was not essential that the contracts considered singly be unlawful as in restraint of trade. Separately considered each of the contracts might have been wholly innocent, but acts absolutely lawful may be steps in a criminal plot. The court condemned the contracts because each contract was part of the scheme or plot. In United States v. Pacific d> Arctic Navigation Co. and others, the defendants, who were not competitors of each other, formed a continuous line of transportation by water and rail between certain ports. They established a through route and joint rates with each other, but refused to do so with an independent company operating on part of the through route. If the agreement between defendants in that case had been entered into from natural reasons and from a judgment of the greater efficiency of the defendants' lines as instruments in the transportation than the independent lines, and if the refusal to conclude through routes and joint rates with the independent had been based on