give any orders to any other dye house other than the Farbenfabriken of Elberfeld Company, for which he was the manager. He promised me that if I would do this that I would have no further trouble in getting the graft which was due me on all the orders, but that he would bring me the graft due me on all orders himself personally to my house every month. This promise he kept; and after this time, every month, during week days from eight to nine in the evening, two or three times each month, Mr Keppelman came to my house and paid me the graft money which was due to me.

In the meantime, Mr Litchfield had left the employ of the Farbenfabriken of Elberfeld Company; and on the following occasion when Mr Keppelman came to my house, on a Sunday, about the end of February 1911, I asked Mr Keppelman why he had let Mr Litchfield go but still retained in his employ Mr Sheppard. Mr Keppelman told me that Mr Litchfield was too old to train in the business; that Mr Sheppard was still young and could be trained as he, Mr Keppelman, wanted to train him. Mr Keppelman also told me that he had another salesman who did the same thing as Mr Sheppard-that is, he retained part of the graft money that was due dyers-but that he had succeeded in training him so that he was now one of the best men in his employ. Mr Keppelman did not mention his name. On the Sunday that I had this conversation with Mr Keppelman, he did not pay me any graft money. He merely made a personal call to talk with me about matters. On this same occasion Mr Keppelman asked me if I knew a dyer named August Dady. I told him yes, I knew him, and that he had worked as a boss dyer for the P. O. Dyeing and Finishing Works. Then Mr Keppelman told me that he had had the same trouble with Mr Litchfield and Mr Dady as he had had with Mr Sheppard and myself; and that Mr Litchfield had not paid over to Mr Dady all the graft money that was due Mr Dady for orders for dyestuffs that he had given for the P. O. Dyeing and Finishing Works. Mr Keppelman also said that it was through trouble such as this that he had lost a great many orders, and that he had a great deal of worriment and unpleasantness over these things.

'While I was at K.'s, A. B. tried to introduce a new dye for another Company into the mill, but I stopped this and made the dye streak all the hosiery dyed by it, by secretly putting chlorate of potash in the double bottom of the tub. I did this while the chemist for this new company, A. B., and the manager of K.'s, were looking on at the experiment, but

they never suspected me. I felt I was justified in doing this not only because I was getting ten cents a pound from the . . . Company, which the new Company never offered to pay me, but also because the new dye was not really so good as the old dye and much more expensive in the end. By doing this trick I saved K.'s at least fifty dollars a week.

From Norristown this deponent moved to Utica, N.Y., where he worked for the R. S. Company and received graft from Kalle & Company.

'I was paid (he states) by Ervin Smith, salesman for Kalle & Company. He paid me from five cents a pound to twentyfive cents a pound for all dyes sold by Kalle & Company while I was there. When I first went there, Smith was afraid to approach me about graft, and he got Albin Benedict, the former dyer for the R. S. Company, to write me three letters explaining how graft was paid him while he was in that mill, so that I would understand about it. Then Smith wrote me, enclosing a slip showing how much was due me for two stuffs sold me by Kalle & Company-one a softener and the other a cotton yellow. After I was at the R. S. Company about four months, McAdams, the treasurer of the Company, sent for me and wanted to know if graft was being paid to me. I said No," and McAdams said he didn't believe me, and wanted me to explain how it was done. I refused, and the upshot was I resigned. After that I couldn't get a job for love or money in New York State, and I believe McAdams must have put me on a black list. I went to several mills in the neighbourhood and couldn't get a job.

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'After I lost my job at the R. S. Company, Benedict sent for me to come to see him at his hotel at Troy, N.Y., which he had bought out when he retired as a dyer. He sent me my railroad ticket. He was afraid I had betrayed him to the R. S. Company. When I got there, he and Smith were waiting for me and demanded the letters they had written to me. I said I had burned them. They said they didn't believe it, and prepared an affidavit for me to sign, stating that I never received graft from Kalle & Company, that I never received letters from Benedict, etc. All the time they kept giving me whisky until I was about half-full. Then they brought in a man who they said was a Notary Public, but they couldn't find any Bible; and Smith finally said, "Well, we don't need any Bible, just sign your name here anyway, Chris." Then I signed it, because I knew it was no good; the man was not a Notary, and I couldn't swear because they couldn't find a Bible.'

The imagination of the manager of the Farbenfabriken Company was stirred to activity when other dye competing Companies (probably English) threatened to gain a footing. How this emergency was handled appears in the affidavit of William Voris Gundy (already mentioned), who says:

"In addition to the facts that I set forth in my previous affidavits, among other things I now recall that, after going to work for the Farbenfabriken of Elberfeld Company, some time after first working for them-possibly in the year 1904while I was working as head chemist in the laboratory of the Farbenfabriken, Mr Keppelman, the manager, sent for me to come up to his office (as he always did when he had instructions for me), and told me that they had been furnishing dyestuffs for a certain mill in Philadelphia-the name of which mill I do not recall-and that the dyer of this mill was working in the interests of the Farbenfabriken and had informed Mr Keppelman that a competitor was trying to get into this mill and displace the Farbenfabriken's dyestuffs; and Mr Keppelman asked me to experiment in the laboratory on different chemicals in order to find the right kind of a chemical, or combination of chemicals, that would successfully spoil and ruin the dyestuffs of this proposed rival. The idea was that this chemical would form a very small package and could be adroitly carried by the dyer, or his second man under his directions, and dropped into the dye tub while they would be casually passing by, and thereby ruin the dye bath.

'I named several chemicals to Mr Keppelman as being the proper chemicals to do this, and among other things that I named I remember mentioning zinc dust. Mr Keppelman said these chemicals were all right so far as spoiling the dye was concerned, but that it would go too far and destroy too much of the colour, so that the game would be almost instantly detected. On the contrary, Mr Keppelman said what they wanted was simply something to make it bronzy or streaked, which would be sufficient to affect the dye, ruin the goods dyed, and prevent the competitors from getting the business.

'I then went back to the laboratory and worked on different chemicals and combinations of chemicals; and, according to my present recollection, I worked at this for about a week before I succeeded in finding the right kind of a combination or chemical preparation that would do what Mr Keppelman wanted. I finally succeeded in effecting and Vol. 232.- No. 460.

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making this preparation, and gave it to Mr Keppelman. I have no doubt it was sent by him in some way to the dyer and accomplished its proper purpose, as I never heard any objection to it afterwards.

'At other times after this I remember on various occasions, at Mr Keppelman's request, I would either give him the names of different chemicals that would affect and spoil various dyes, or else I would work on chemical preparations that would accomplish this purpose. These chemicals and preparations would then be given to him by myself, and I would hear nothing more about them, but I am sure they must have gone out to the dyers as they were intended, and successfully accomplished the purpose for which they were intended.

'Even before I was asked to make this first preparation by Mr Keppelman, and while I was working in the chemical laboratory, I knew from my predecessor there as head-chemist, X. Y., who now lives at . . ., that these chemical preparations were being constantly made by the Farbenfabriken in order to spoil the dyestuffs of rival and competing houses.

'Mr Y. had been there quite a number of years, and was doing this work, among his other duties for the Farbenfabriken, during all the time I was there, and had been doing it before I was employed by them. I think it was about 1904, or thereabouts, that Mr Y. left. I remember that Mr Y. was somewhat conscientious, and this was one of the duties that he was called upon to do for his employer that he rather balked at.'

What happened to the chemicals invented by Mr Gundy is shown in the evidence of Richard Meyer:

'On many occasions, I recall that, although the exact dates do not occur to my mind, dyestuff was brought in and tried from other Companies, but on each occasion I so managed that it would either spoil the goods or be so unsatisfactory in its result that the mill believed that the dyestuff from these other Companies was no good, and therefore would not buy from them.'

Mr Keppelman kept several motor cars, and the evidence of his chauffeur, C. S. Kille, has interest:

'I remember on very many occasions taking Mr Keppelman in his automobile to different houses of men whom I afterwards ascertained to be dyers. On some of these occasions, according to Mr Keppelman's instructions to me, I

would stop the car around the corner from the address where we were going, and Mr Keppelman would get out and walk around the corner to the house. Mr Keppelman would tell me on these occasions, if any one asked whose car it was, not to tell. Among the addresses to which I often took Mr Keppelman are the following:

1823, E. Tioga St (address of William Fischer, dyer). 1821, E. Lippincott St (address of August Dede, dyer). 1906, E. Venango St (address of Chris. Eisfeld, dyer). '615, Locust Avenue, Germantown (address of Tommy Driscoll, dyer at Bradford Mills).

'1347, Hunting Park Avenue (address of Kirgeis, dyer; and William Zipper, chemist for Farbenfabriken).

1217, E. Allegheny Avenue (address of E. F. and H. F.). 'Also a lettered street in Olney (address of William Schumann, Jnr., dyer for U. V. W.).

'Also I took him down to a beer saloon in Chester, I do not just remember the street, where he met men. On some occasions we would pick men up on the street who looked to me to be dyers, by appointment, and after taking them around in the automobile for an hour or so would let them out again. I also went to many other addresses with Mr Keppelman in the car, which addresses I cannot just recall now, but will remember them later on or when my attention is particularly called to them. I remember once taking Mr Keppelman in the car on a Sunday afternoon out Broad Street, Miss Gaul accompanying him, and at Mr Keppelman's instructions, I stopped the car on Broad Street and he gave me a long envelope which felt to me as if it was full of "dough," and at Mr Keppelman's instructions I took this around the corner in Allegheny Avenue, I think it was 1912, Allegheny Avenue, and delivered it in person to Mr H. F.

'Mr Keppelman never told me directly what he was doing, but I had a good idea that he was doing something crooked with these dyers right along, and that these trips, conferences and appointments were for this purpose. He always carried with him a portfolio bag and sometimes a black grip, and sometimes had a revolver in the black grip for some purpose.'

Mr Keppelman, who has acquired more or less fame for the ingenuity and thoroughness of his methods, hired a yacht during the summer, whose cruises became popular in certain dye circles and whose career has since attracted perhaps undue interest. Modesty made it extremely difficult, except in the close confidence of conversation,