LEGAL PHASES OF COOPERATIVE ASSOCIATIONS, 47 
the Secretary of Agriculture is then required to file a certified copy 
of the order issued by him, together with certified copies of all records 
in the matter, in the District Court of the United States in the ju- 
dicial district in which such associaiion has its principal place of 
business. The Department of Justice has charge under the act of the 
enforcement of such order. The District Court of the United States 
is given jurisdiction to affirm, modify, or set aside the order or to 
enter such other decree as it may deem equitable. 
FEDERAL TRADE COMMISSION. 
UNFAIR COMPETITION. 
The act *® of September 26, 1914, created the Federal Trade Commis- 
sion. The act states that unfair methods of competition in commerce 
are unlawful and provides that “the commission is empowered and 
directed to prevent persons, partnerships, or corporations, except 
banks and common carriers subject to the acts to regulate commerce, 
from using unfair methods of competition in commerce.” 
The term “ commerce” as defined in the act means commerce, in- 
terstate or foreign, or in any Territory of the United States or the 
District of Columbia. The term “ unfair competition ” is not defined 
in the statute. At common law unfair competition consisted in the 
palming off by one vendor or manufacturer of his goods as those of 
enother.*° The term “unfair competition” as used in the act un- 
doubtedly means all that it imports at common law and, in fact, it 
apparently has a broader significance and scope than it nad at com- 
mon low. 
The act provides that the commission after a hearing may issue an 
order requiring the person, firm, or corporation involved to cease 
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- 
pary of Armour & Co., and that it was not an organization of farm- 
© 38 Stat. 717. 
_ # Howe Scale Co. v. Wyckoff, 198 U. S. 118. 
