LEGAL PHASES OF COOPERATIVE ASSOCIATIONS. 47 
and desist from unfair competition. In the event the order is not 
obeyed, the commission may apply to the Circuit Court of Appeals 
of the United States within any circuit where the method of compe- 
tition in question was used, or where such person, firm, or corpora- 
tion resides, for the enforcement of its order. Any party against 
whom an order is issued may appeal to the Circuit Court of Appeals, 
from which court an appeal lies to the Supreme Court of the United 
States. 
A few illustrations will shed light on the scope of the work of the 
commission. In 1919 the commission issued an order against Ar- 
mour & Co. and the Farmers' Cooperative Fertilizer Co. It ap- 
peared that the Farmers' Cooperative Fertilizer Co. was a subsid- 
iary of Armour & Co., and that it was not an organization of farm- 
ers, as the name implied. The order required the Farmers' Coopera- 
tive Fertilizer Co. to show on its letterheads and on its places of 
business that it was a subsidiary of Armour & Co. 
Attempts by an association of harness manufacturers and by a 
saddle-makers' association to compel the separation of the wholesale 
and retail harness dealers by refusing to recognize those who engaged 
in both the wholesale and retail trade as authorized jobbers and to 
prevent the sale by manufacturers of accessories to such persons was 
held in a certain case to be unlawful and subject to action by the 
Federal Trade Commission. In this case, as indicated, the two asso- 
ciations attempted through the membership of each to prevent manu- 
facturers, jobbers, and wholesalers from selling direct to consumers. 42 
The Winsted Hosiery Co. has for many years manufactured un- 
derwear which it sells to retailers throughout the United States. It 
brands or labels the cartons in which the underwear is sold as " Nat- 
ural Merino," " Gray Wool," " Natural Wool," " Natural "Worsted,'' 
or '"Australian Wool." The Federal Trade Commission 43 instituted 
proceedings against this company, calling upon it to show cause why 
use of these brands and labels, alleged to be false and deceptive, 
should not be discontinued. After appropriate proceedings an order 
was issued which directed the company to — 
Cease and desist from employing or using as labels or brands on underwear 
or other knit goods not composed wholly of wool, or on the wrappers, boxes, or 
other containers in which they are delivered to customers, the words " Merino.'' 
" Wool," or " Worsted," alone or in combination with any other word or words, 
unless accompanied by a word or words designating the substance, fiber, or 
material other than wool of which the garments are composed in part (e. g., 
" Merino, Wool, and Cotton " ; " Wool and Cotton " ; " Worsted, Wool, and Cot- 
ton " ; " Wool, Cotton, and Silk "), or by a word or words otherwise clearly indi- 
cating that such underwear or other goods is not made wholly of wool (e. g., 
part wool). 
42 Natl. Harness Mfg. Assoc, v. Fed. Trade Commission, 268 Fed. 705. 
43 Federal Trade Commission v. Winsted Hosiery Co., 42 Sup. Ct. Rep. 384. 
