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BOSTON PUBLIC LIBRARY 

" 11111 
7 504 4 



3 9999 063 



OFFICE OF NATIONAL RECOVERY ADMINISTRATION 
DIVISION OF REVIEW 



op 



HISTORY OF THE CODE OF FAIR COMPETITION 
for the 
LADIES HANDBAG INDUSTRY 



WORK MATERIALS NO. 71 



Administrative Section 
March, 1936 



HISTORY 

of the 

CODE OF FAIR COMPETITION 

for the 

LADIES HANDBAG INDUSTRY 

Approved Code No. 332 



Author: Oliver W. Pearson 



Robert C. Ayers 
Chief, Histories Unit 



QP11 



FOREWORD 

This history of the Code of Fair Competition for the Ladies 
Handbag Industry is mimeographed in order to make available a 
sample of the code histories prepared "by the Division of Review. 
A similar service Trill he rendered in connection with certain 
other code histories. 

In order to get a complete picture of National Recovery Ad- 
ministration materials applicable to a given industry, one must 
visualize such a documented code history as this supported by 
the three volumes of evidence which were sent to the President 
at the time the code was recommended for his approval, plus any 
studies in this field either by the Division of Research and 
Planning or by the Division of Review of the National Recovery 
Administration, plus the vast amount of material in National Re- 
covery Administration files which was developed in connection 
with the formation and administration of the code. These con- 
stitute a veritable treasury of information concerning the 
operations and problems of industry. 

This history contains a documented account of the formation 
and administration of the code; the definition of the industry 
and the principal products thereof; the classes of members in 
the industry; and account of the sponsoring organizations, the 
conferences, negotiations and hearings which were held, and the 
activities in connection with obtaining approval of the code; 
the organization and operation icf the code authority, the dif- 
ficulties encountered in the adr.ini strati on, the extent of com- 
pliance and non-compliance, and the general success or lack of 
success of the code; and an analysis of the operation of the code 
provisions dealing with wages, hours, trade practices, and other 
provisions. These and other matters are canvassed, not only in 
the terms of materials to be found in the files, but also in 
terms of experiences of the Division Administrators, Deputy Ad- 
ministrators, Assistant Deputy Administrators and others con- 
nected with the code formation and administration. 

At the back of this history will be found a brief state- 
ment of the studies .and work undertaken by the Division of Review. 



L. C. Marshall 
Director, Division of Review 



March 14, 1936 



9811 - i - 



Page 
Letter of Transmittal 
Preface 
Code and Amendments 

I. GENERAL INFORMATION 

A. Definition of Industry 2 

B. Definition of Industry Member 4 

C. Statistics of Industry 6 

II. HISTORY OF CODE FORMULATIO N 

A. Sponsoring Organization 14 

B. From submission of first Draft 21 

C. Public Hearings 23 

D. From Public Hearing to Approval 25 

III. CODE ADMINISTRATION 

A. General Preliminary Discussion 45 

B. Organisation 51 

C. Budgets and Bases of Assessment 63 

D. Administration of Code 67 

IV. OPERATION OF CODE PROVISIONS 

A. Definitions 82 

B . Wages 83 

C. Hours 85 

D. Other Labor Provisions 86 

E. Adminis trative Provisions 90 

F. Price and Accounting Provisions 90 

G. Trade Practices 92 

H. Other Provisions 96 

V. RECOMMENDATIONS 

A. Undesirable or Unenforceable Provisions 98 

B . Compl iance 98 

C. Limitation on Production 98 

D. Possible Consolidations 98 

VI. PERSONNEL 

A. Personnel connected with Code 101 

B. Administration Member' s Report 

Appendices Exhibit N 

VII. APPENDICES 

A. Exhibits A to Z and Al to Gl. 

VIII. INDEX 



9811 -ii- 






January 7, 1936. 



MEMORANDUM 



TO: L. C. Marshall, 

Director, Division of Review 

FROM: Oliver ¥. Pearson 

SUBJECT: History of the Code of Pair Competition 
for the LADIES HANDBAG INDUSTRY. 



There is transmitted herewith the History of 
the Code of Fair Competition for the Ladies Handbag 
Industry. 

This History was compiled in this office and 
was written in accordance with the model outline 
issued on July 10, 1935. 

It is believed that this record, as submitted, 
adequately reflects the History of the Code of Fair 
Competition for the Ladies Handbag Industry, 



Oliver W. Pearson 



Approved: 



Walter Mangum, Director, 
Industry Section #3. 



9811 - iii - 



P REF AC JS 

The Ladies Handbag Industry was founded in this country some fifty 
years ago and entirely manned by imported craftsmen. It continued for 
many years as a craft trade and only of quite recent years had it evolved 
into one of mass production with an increasingly large use of machinery. 

Prosperous for years, almost beyond belief, net returns to owners 
very large, workmen or craftsmen earning $150 - $200 and in many cases 
$300 weekly it is not difficult to understand the mental condition that 
came into being, when machinery came upon the horizon, mass production 
threatened, labor became restive, and finally, the depression arriving 
with its consequent loss of profits. To all of these factors can be 
ascribed the unrest that existed when r.I«R»A» was placed upon the statute 
books, but notwithstanding the disagreeing view points all had a belief 
that a Code was necessary, and would prove as it later did, of great 
benefit. 

Reviewing the eighteen months I spent with the Ladies Handbag In- 
dustry and its Code Authority as its Administration Member, looking back 
over the other industries, some ten in number, to which I was accredited, 
I realize today the outstanding quality of the work done by the Handbag 
Group. 

Perhaps other industries gathered more complete data, such for in- 
stance Millinery and Men's Hats, but none better welded together con- 
flicting interests, none accomplished more in finding the common ground 
upon which to stand then did this sorely beset handbag Group. 

Beginning with the days immediately preceding the enactment of the 
U.I.K.A. hearts and minds of industry were filled with malice, hatred, and 
all uncharitable::ess. This state of mind continued throughout the code 
negotiation period and did not disappear until some three months after the 
code went into operation, and the last months of the Code era found man- 
ufacturers more, cohesive, more thoughtful in their relations with each 
other, more inclined to look at their problems from the view point of in- 
dustry at large. 

I would not have it believed that the millennium arrived but certain 
it is a degree of intelligence was injected into what had been a purely 
selfish outlook and all bade fair to profit accordingly. 

In those l«st days one eould feel in the air the different atmosphere 
that pervaded deliberations, one trade organization had come into being 
instead of several who hitherto had been at each others throats, and from 
what I was told by a number of manufacturers the industry at the end of its 
first eode year was able to show at least some financial statements in 
black ink, the first in several years. 

Close study has been made of records in our files as well as those of 
the code authority in New York. Many things stated are of necessity based 
upon my own recollections, but checked with officials of the late code 
authority, and I believe the following chapters represent a fairly com- 
prehensive history of this code. 



9811 



-iv- 



-1- 



CTN SEAL I iffO -ftiATI OH 

Definition of Industry 
Principal Products 
Products under other Codes 
Definition of Industry Member 
Classes of Members 
Statistics 



9811 



I. GENERAL INFORMATION 

In conroiling this history references were made to all available 
material in Jashington and New York. This included: 

1. PRIMED CODE 

2. Volumes I, II and III of Code 

3. Volumes I, II and III of Amendments 

4. Volumes A and 3, Central Records Section 

5. Administration Orders 

6. Depv.ty' s Files 

7. General Files 

8. Research and Planning Files 

9. Government Agency Reports 

10. Code Authority Reports in re Budgets 

11. Code Authority files in Hew York 

(Now in possession of the national Authority 
for the Ladies handbag Industry, 347 Fifth 
Avenue, New York.) 

12. Administration Members Files, Hew York City 
(How in process of incorporation into General 
Files, Washington, D. C.) 

13. Personal contacts with late Code Directors 

14. history of Industry by Ab. Mitten thai, Code 
Director and filed with Dr. L. C. Marshall 
about September 15, 1935. 

15. Bulletins issued by the Code Authority. 

A. Definition of Industry 

The Code as originally proposed August 11, 1953, by the 
Associated handbag Industries of America, Inc. submitted the following 
as the definition: - 

"The term 'handbag industry' as used herein is 
defined to mean the manufacture and/or whole- 
sale distribution of ladies handbags, pocket- 
books and purses." 

"The term 'person' as used herein shall include 
natural persons, partnerships, associations 
and corporations." 

"The term 'employee' as used herein shall include 
every person actively engaged in the production 
and/or wholesale distribution of. products of the 
handbag industry as herein defined." 

(Exhibit A - part 2, Page 1.) 

As defined in mimeographed Revised Draft November 6th, 
1933 it read: - 



9811 



-3- 

"The term ' Industry' as used herein includes 
the manufacture of ladies' handbags, pocket- 
books and purses." 

(See Exhibit A - Part 4.) 

As Revised "November 24, l f J33 it read: - 

1. "The term 'Industry' a.s used herein includes 
the manufacture of ladies' , misses, and 
childrens handbags, pocketbooks, and purses, 
manufactured cf oxiy material of any kind or 
nature. " 

In the drafts of December 3, December 12, December 31, 1933, 
it remained withoixt change. 

(See Exhibit A part 6, aage 1: part 7, page 1: part 8, page 1.) 

The approved code Article II, Section 1, reads: 

"The term 'industry' as used '. terein includes the 
manufacture of ladies', misses', and children's 
handbags, pocketbo ks, and purses, manufactured 
of any material of any kind or nature. • The term 
'industry' shall not include, however, the 
manuf ac tur e of handb ag s , p o ck e tb o ok s , pur pes and 
mesh bags manufactured in whole cf metal." 

The changes made resulted from Tar ious conferences and upon ob- 
jection by A. J. Barrenboim and Mr. Newman of the Legal Division, 
counsel to the Division (see generad files Code Record). They served 
to clarify the definition in that they more clearly specified the 
lines sought to be governed, and by eliminating the term "wholesade" 
prevent overlap ing with distributing codes. 

The generally accepted meaning of the Code definition included 
shopping ba^s, bathing bags, handkerchief bags, vanity boxes, 
cosmetic ba.gs, and knitting ba,gs. however, t^ remove doubts and be- 
cause of repeated requests from industry for a still clearer defini- 
tion the section was at the close in process of being amended to read: 

"Tie term 'industry' a.s used herein includes 
the manufacture of la.dies' , misses' and 
childrens 1 handbags, pocketbooks and purses, 
a.cp'hng bags, bathing bags, handkerchief 
bags, kiddy- bags, vanity boxes, cosmetic ba.gs , 
knitting bag;: , manufactured of any material of 
any kind or nature. The term, however, si-all 
not include articles commonly manu f :-e tared by 
Luggage and Fancy Leather C-cod". Indust ry for 
traveling purposes, nor ever-night bags for 



9311 



~4- 

whatever purpose u sed , nor a ny article 
manufactured for mens 1 use only , nor 
manufacture of handbags, pocketbooks, 
parses, vanity cases ,. and mesh bags manu- 
facturod in whole of metal . " 

Note the inclusion also of "kiddy bags". These are products of 
a group of some 75 manufacturers who at the time of dissolution were 
being transferred from the Luggage and Fancy Leather Goods Code to 
this Code. 

(See Minutes I.ieeting No. ,35 - Jan. 3, 1235 and 
correspondence general files) 

Considerable opposition to this last proposed definition was 
raised by the Sanitary .' waterproof Specialties Industry, because of 
the inclusion of "bathing bags" and "cosmetic bags"; for many such 
v/ere strictly of waterproof or rubberized materials. After several 
conferences with Mr. Kenlrici: of the Sanitary C-. .Taterprocf Specialties 
Code Authority, this difference was smoothed out. There was only one 
large manufacturer, (Kleinert Company) and three small ones affected 
and all but one, who had not yet been contacted, had agreed to use 
Ladies handbag labels, in all items which) bordered, on this code. (See 
Code Record files) 

1. principal. Products 

Ladies - Hisses - Childrens 
handbags 
Pocketbooks 
Purses (See Article II, Section 1 of Code) 

2 . Products also unde r n ther Codes 

Kiddy Bags (Luggage and Fancy Leather Goods) 

3athing Bags (Sanitary C. '.Jaterprcof Specialties) 

B. Definition of Industr y Member 

In the draft of August 11, 1933 the term was stated.: 

"The term 'person 1 as used herein shall 
include natural persons, partner ships, 
associa.tions and corporations. 

"The term 'employer' as used herein shall 
include every person actively engaged in 
the production and/ or wholesale distri- 
bution of products of the handbag indus- 



9811 



-5- 

try as herein defined." 

(Exhibit A - Part 2) . 

In the August IS, 19L T 3 draft it remained as stated in August 11 
form, hut in the November 6, 1933 form it read: - 

"The term 'emoloyee' as used herein includes 
any oerson engaged in any ohese of the industry, , . 
in any capacity, receiving compensation for his 
services, irresnective of the nature or method 
of -nayment of such comnensation." 

"The term 'enrol oyer' as used herein includes 
anyone for whose benefit or whose business 
such an emoloyee is engaged." 

"^he term 'member of this industry' includes 
anyone engaged in the industry, either as an 
emoloyer or on his own behalf." 
(Exhibit A - Part 4) 

In the revision of November 24, 1933 it read:- 

"The term 'emoloyee' as used herein includes 
any oerson engaged in any ohase of the indus- 
try, in any caoacity, receiving compensa- 
tion for his services, irresoective of the 
nature or method of oayment of such comoen- 
sation." 

"The term 'Emoloyer' as used herein includes 
anyone for whose benefit or in whose business 
such an emoloyee is engaged." 

"The term 'member of the industry' includes 
anyone engaged in the industry, either as , ' - 

an emoloyer or on his? own benalf and either 
as manufacturer, manufacturing jobber or 
contractor. " 
(Exhibit A - Part V) 

In the December 8, 1933, December 12, 1933 and December 21,' 1933 
revisions (see Exhibit A, parts 6-7-3) and- in the approved Code, 
Article II, Section 4, it remains as above and quoted below:- 

"The term 'member of the industry' as used 
herein includes anyone engaged in the in- 
dustry, either as an emoloyer or on his own 
behalf and either as manufacturer, manufac- 
turing jobber, or contractor." 



9811 



-6- 

llote: The definition of industry member includes in addition to 
ifarrufacturer - "manufacturing jobber or contractor." The manufactur- 
ing jobber is one who generally uses a' contractor to make goods for 
him and to whom he supplies all or part of the materials used in. the 
making of bags. 

Contractors were of the usual type 'who did various operations on 
bags, and are such as may be found in all garment industries. Seme of 
these contractors, however, made complete bags and some re-let portions 
of this work out to homeworker?. T.if-se contractors were subject to 
the previsions of the Code, but were not assessed for the expense of 
administering the Code. 

(See classified list of Industry Exhibit B - part 3) 

1. Classes of Members 

There is to be found in Exhibit B, Parts 1 
1 and 2 a classified list of manufacturers 
showing the kind and character of goods 
manuf ac tur ed . 

C. Statistics of the Industry 

Prior to the adoption of their Code this Industry had never 
attempted to gather factual data, rod in fact had seemingly no idea 
of the value of such. Under a code and because of an appreciation 
by Code Directors of the value of such materie.1 there began the 
collection of data that at the close promised tc be of great service. 
Progress was naturally slow because of industry' s inertia., due to 
their lack of understanding, and it is also to be believed, to a fear 
of disclosing and facing facts* 

Department of Commerce figures bulletined ^iy Code Authority 
Vol. II of Bulletins issued No« Four, under date of December 21, 1934 
shows: - 

1953 1931 1929 

ho. of establishments 218 260 290 

Cost of materials, fuel $15,293,920.00 .)22,600,817.00 $35,351,605.00 
etc. 

Value of products 28,299,004.00 43,147,053.00 68,627,515.00 

Value added by manu- 
facture 13,000,0.34.00 20,546,236.00 33,275,910.00 



(Indicating a sharp decline from 1929 to 1933) 
See Exhibit C. 



9811 



~7- 



Comparative Costs of Labor between Pew York are:-, and outside 
Hew York area. Compiled in Spring 1935 by the Code Directorate. 



57 YOHK A22A. 



Bags to retail at 5C;' $15.00 to .',18.00 gross 
(imitation leather) 

Bags to retail at $1.00 ,;30.00 to $36.00 gross 
(imitation leather) 

Bags to retail at $1.95 (551.00 to $57.00 gross 

Bags to retail at i)2.95 $72.00 to $84.00 gross 



0UT3IDS 'NEV/ YGZK A35A 
$ 9.00 to $12.00 gross 

$13.00 to $24.00 gross 

$33.00 to $39.00 gross 
$45.00 to $51.00 gross 



Bags to retail at $4.95 $96.00 to 120.00 gross $60.00 to $72.00 gross 

These figures are based on the present labor rates now being paid in 
the industry. Any changes in ra.tes because of the semi-skilled 
definition or increase in wages due to a Union agreement, may alter 
the conditions. 

The National Authority for the Ladies handbag Industry 
successors to the Code Authority under date of 
September 1935 gave me the following: - 



*(a) 


*(b) 


(c) 


(a) 


(e) 



Units Engaged 
Contractors 
Workers engaged (est) 
Capital (est) 
Total volume (est) 



379 

146 

15,000 

;;io,ooo,ooo.oo 

$40,000,000.00 



and remark that five years ago fifteen units each did in 
excess of $1,000,000.00 annually whereas in 1935 but one 
will reach that figure. 

In answer to an inquiry to the hational Authority dated 
September 12, 1935, we are given the following: 
Figured on dollar value it is believed that 



50$ of bags a.re ma.de of Leather 
50, "j of bags are made of Cloth 

(Imitation Leather) 



9811 



-8- 



Figured on units engaged 

30/5 manufacture Leather 

70,1 manufacture Clot, (imitation leather) 

(See Exhibit D) 

Research and Planning files disclose in a report prepared 
by James P. Davis, February 8, 1934: - 

Source: Bureau of Census 1923 - 1031 

Report from Industry 1932 - 1933 

1929 1931 and 1932 

Annual volume apprcx. ^7, 000, 000 )3 5, 000, 000 

Ei.iPLOYi.aiIT 

Value of 
Products 
Wage Earners (Thousands) 

1921 2715 $15,085 

1923 5518 32,732 

1925 6326 43,105 

1927 3370 57,435 

1929 10430 68,028 

1931 8747 43,147 

1932 12000 35,000 

1933 120C0 35,000 

NOTE: - Above 1 \ should be deducted to cover production 
of lien' s pocketbooks and bill folds. (These are 
net included under this code.) 
(See Exhibit E, pages 1 and 2) 

Code Authority Report , Liarch 1935 , aoaws: - 

* Number of estrblishments 500 

* 'I to be assessed 325 
Annual sales for 1934 & 1935 $35,000,000 
.Amount of sales upon which assess- 
ments have been collected $26,093,664 
Volume of Sales upon which assess- 
ments will be collected, approx. $ 7,000,000 
Number of employees as of December 

31, 1934 15,000 

Total payroll of industry $ 9,000,000.00 



9811 



~9~ 



Geographical Distribution of Manufacturers: 



Eastern 
Southern 
Midwestern 
Pacific Coast 



)23, 87 3 ,650.00 

601,481.00 

1,392,490.00 

226,043.00 
$26,093,664.00 



91.50 



2, 


,30 


5, 


,33 


0, 


,87 



100.00 



Areas Defined 

Eastern: 

Southern: -. 

i.iidwest: 

Pacific: 



Hew York; Massachusetts; Connecticut; 
Hkiode Island; New Jersey; Pennsylvania: 

Maryland; Virginia; Florida; and Texas: 

Illinois; Wisconsin; Missouri; and Ohio: 

Washington and California. 



(See Exhibit E, page 1. 3udget) 



NOTE: - 



The seeming disparity is to be explained in 
one case by giving a total without breakdown, 
in the other by separating manufacturing 
units from contractor units. 



9811 



Files of Labor Advisory Board found in General Files: 
PGCKETBOOKS, PURSES, CAHD CASES (Primarily Leather) 
(U.S. C1TSUS FIGUHES) 
HGUitS 



Pocketbook; 



■urses - card cases - 1929 



No. of 
Est. 

290 



Wage Earners 
Ave, for year 

10,430 



40 hrs. 

■under 



Over 40 
Under 4-5 



45-43 hrs. Over 48 but 
Inclusive not over 54 



(7) 180 (176) 6,248 (53) 2,185 (32) 1,755 



CGNDITI0N OF I7DU3THY 



1*0. 




Wage 




Cost 




Added 


Estr 


"0. 

253 


Sam. 


V'a^es 
10,036,605 


of '..at. 
21,917,931 


Value 
41,926,190 


Value 


1931 


8 , 545 


20,003,259 


1929 


290 


10,430 


15,229,422 


35, 351 ,605 


63,627,515 


33,275,910 


1927 


257 


8,570 


13,169,509 


29,613,524 


57,344,655 


27,726,131 


1925 


207 


5,513 


7,291,112 


16,235,332 


32,731,725 


16,495,843 



DISTHIBUTIGN 1929 



New York 192 Est. 

Pennsylvania 17 " 

Massachusetts 17 " 

New Jersey 8 " 



6,101 workers 
1,040 " 

696 " 

300 " 



10,952,801 wages 47 , 631 ,431 value 
957,711 " 4,306,827 " 

709,779 " 3,540,411 " 

962,623 " 3,656,966 " 



Then Ohio, Illinois, Missouri, California., Wisconsin, and small amounts 
in other states. 

AVERAGE ANNUAL ."."AGE 



U. S. 



1931 - )1,180 
1929 - 1,460 
1927 - 1,556 



9811 



-11- 



?ages of certain women on various operation's in a Springfield, I,Iass« 

factory: 





Se-ot. 1935 


Hourly 








Se- 


^t. 1928 


' "ou rl y 


Hour: 


i Sarnings 


Hate 






Tours 


E; 


arnings 


Rate 


172|- 


64.60 


37f 




Change 


156 




91.43 


58-| 


169| 


61.26 


36 




in 


169 




72. 1-2 


43 


178 


49.85 


38 




1336 


170c 




58.03 


34 


165-| 


57.36 


34vV 




from 


163 




80 . 48 


49* 


104£ 


37.19 


rrr- 1 


di 


?y wo ri- 


133i 




66.40 


48 


183^ 


76.05 


41 




te 


174^- 




35.34 


49 








piece work 











Women ' s Eareau 

Proportion of N. Y. State production to total production 

1929 

Total 
U.S. $68,627,515 - value of products 

N. Y. 

State 47,631,431 - » " " 



66.31/j oi t.ie total number oi establi aliments 



58.49,* of the total numDer of wage earners 



Of 192 plants in N. Y. State, 167 are in New York County 

9 are in Kings County 
5 are in Queens County 



;f 17 plants in Penna. , 13 are in Philadelphia, 



9811 



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Picture of Nand 3ag_ Industry 



As given cf July 1, 1934- compiled by Code Directors: (See C-eneral 
files) 



In 1904 - The entire nation did $0 , 500, 000 worth of "business 

In 1929 - " " " " $67,000,000 in leather bags 

1,000,000 in evening and 

fabric bags 
4,000,000 in bags to retail 
for riLOO 



As of July 1st The volume of business v/as )40 , 000 , 000 . , out of 

1924 which $23,090,000. covered bags to retail fx'om 

20;'- up to $1.00, and the balance for bags from 
$1.95 up to o25.00 each. 

35/t of the Nation' s retail business in hpxidbags 

is done between Thanks giving Day and December 24th. 

Bags at $2.95 and up are made by hand in New York 
City. 

Dags from 20'/- to $1.00 are made by the new and 
modern machinery in the out-of-town factories. 



PRODUCTION IN UNITS 



In 1929 .7e produced 2^,000,000 units 



In 1934 as of 

July 1st We produced 70,000,000 units from 20^ up to $1.00, and 

4,500,000 " " $2.95 and up 



Code Authority Monthly Reports 

(See Exhibit F) '»7a.ge Reports - Sales Volume - 
Unit Volume - Classification of workers engaged. 



9811 



-15- 



HISTORY OF CODE FORMULATION 



Sponsorin, ■■ Organizations 
Officers, Code Committees 
First Draft to Public Hearing 
Public Hearings 
Approval 



9311 



-14- 



I. HEE3BEFCES PPP2 HAD3 TO: 

1. Commercial Agencies - no avrilable material. 

2. Department of Commerce cennas of manufacturers - no segregated 
material. 

3. Department of Commerce census of distribution - no segregated 
material. 

4. Research and Planning bulletins and records. 

5. Code Authority files. 

6. Code Authority Bulletins (ErPiijit C) 

7. Administration members' file. 

8. National Authority of the Ladies Handbag Industry, 347 Fifth 
Avenue, I-"e r ' Tor 1 -:. ( Successors to Code Authority.) 

9. General Files. 

10. Monthly Reports Code Authority (P:hioit P.) 

II. HISTORY OP C0D3 POPPULAHOP 

A. SPOPSOPIi G ORGANIZATIONS 

!• Statement re t rue r -o^esontrtion , age anC\ objectives . 
Coc'o Poe'P.r ;s , etc. 

1. While tue first Code, 3r-hibit A, part 1 and 2, with its 
covering letter of transmittal was presented by the Associated Handbag 
Industries of America, Ind. , Per York City, August 28th, 1933, it was not 
the document entered for the first and onl" purlic hearing December 8, 
1933. 

Han'- conferences were held by industry groups themselves, and with 
Deputies, both in New York and Washington, before revisions vers agreed 
upon and the instrument "out into satisfactory shape for that hearing. 

The revised document ''.'as ?im 11"" sponsored oy: 

Associated land'opg Industries of America, Inc., Per; Pork 
Midwest Handbag ano Sma.ll Leather Pares Association Inc., 

Chicago. 
Industrial Council of the Ladies 'fendbag Industry, Kerr 

York. 

Claiming to represent in their combined membership 75> of the 
industry' s volume. (See transcript of hearing December 8, 1933). 

It was mainly through the efforts of Pr. A. Hit ten thai, Chair- 
man me Vice President and Mr. :". Hosesson, Executive Secretary of the 
first named Association that the Code was put into usable shape for the 
public hearing and. that the sponsoring Associations came together to 
jointly appear before the Administration. 

The objects of the first sponsoring organization that presented 
the first code are set forth in the paragraph below: 

9811 



-15- 



"The object of this Association shall" be to secure 
and provide cooperative and or i ted effort in all matters 
relating to the progress, development, welfare or im- 
provement of conditions in the Handbag Industry and in- 
dustries correlated end contributing to and affecting the 
welfare and progress of the landbag Industry in all its 
branches, to foster the trade and commercial interests 
of its members; to secure freedom from unjust and unlaw- 
ful exactions; to inculcate and maintain just and eouit- 
able principles; to eliminate unfair or improper practices; 
to establish and maintain uniformity and equity in the 
customs and commercial usages in the Industry; to acouire, 
preserve, collect, and disseminate business information 
deemed useful, advantageous or valuable to its members 
regarding the handbag Industry; to reform, correct and 
prevent any abuse and adjust commercial controversies, 
misunderstandings or grievances between members or be- 
tween its members and the trace; to enforce its said ob- 
jects and purposes among its members ^ r such disciplin- 
ary and other measures as may be agreed, upon by them and 
as may be provided by its by-laws; and in general to do 
all matters tending to the improvement of the 'landbag 
Industry in all its commercial aspects." 
(See paragraph 3, cage 1, letter of transmittal Exhibit 
A, part 1.) 

This organisation came into being before the Code era. (see page 19, 
this history) . 

"hile there is no documentary evidence of what transpired at the 
various meetings and conferences, members of industry, preferring, I am 
told, not to have written records of their many bitter fights, the writer 
is fully aware of the conditions that existed Ion,? prior to the enactment 
of the JJ.I.R.A. and of those that obtained during the ensuing montus. 

The argument;; presented -ere based upon the labor situation obtain- 
ing in 193 7 >, a situation caused by the migration of industry from its 
first and principal home base Few York City and other contributing fac- 
tors upon which I will touch later. (Page 16, this history) 

The shifting of industry from the Metropolitan City started about 
1928 and 1929 and was caused, it is claimed and I believe cannot be dis- 
puted, by the heavy handed tactics of the labor leadership then in oo^er. 

As more and more manufacturers located their olants in cities an< 
towns outside the Metropolitan area, taking advantage of the cheat) labor 
there to be found, naturally those remaining in New York and under Union 
agreements found competition, which was largely baseci \ipon labor costs, 
almost un-meetable. It was not however until we were well into the de- 
pression years, with a consistent lowering of price floors that real bit- 
terness came into existence. 

The N.I.H.A. having, been written and passed, many New York City manu- 
facturers believed, they saw an opportunity to even up conditions if they 
9811 



-16- 



were allowed to write into a code for their industry, labor classifications, 
wage scales and hours that r/ould make snore difficult the path of the out- 
of-town manufacturers. 

To give a clear cut picture of the conditions that led to the then 
existing situation, I quote from a document filed on or about September 
13, 1935 with the Administration (Dr. Marshall Review Division) and pre- 
pated by the former Code Director Mr. ... Kit tenth 1. (Exhibit G-) 

"Up until the year 1329, more than 95 > of the industry was located 
within the Metropolitan area of Tew York. The industry located in Hew 
York has been in contracturl relations with the Union for almost twenty 
years. In the year 1928, the first manufacturer moved away from the 
unionized centre of Metropolitan New York, and began manufacturing in 
Allentown, Pennsylvania, under non-union conditions. At this time the 
Union minimum wages filed by agreement with the manufacturers in Hew York 
were $45.00 a week for skilled workers. _ Admission of workers to the 
skilled branches were control 1 ed by the Union, so that in some of those 
branches of the industry workers earned on a piece work brsis from $100.00 
to $200.00 in a 44 hour reek. Those manufacturers vho moved from Hew York 
were unpble to obtain skilled workers in their respective localities. 
They were compelled, to employ workers without any oreviovis experience in 
the industry. Machinery heretofore little used, in industiy was invented 
to take the place of many of the operations performed by skilled workers 
in trie Hew York factories. Workers in these new localities were oaid 
$6.00 or $7.00 -oer week, and they worked from 43 to 54 hours a - r eek. " 

"Hith the tremendous difference in labor costs, those manufacturing 
outside of He'' York, "ere able to give greater values or sell for less, 
with the result that the manufacturers operating in Hew York under Union 
conditions were forced to meet this competition by sacrificing their pro- 
fits. The success of the few who moved away, offered the incentive for 
others to follow. In the year 1933, only about 50,"£ of the industry still 
remained in the Metropolitan area, of New York. Those who moved or opened 
new factories located in the eastern states, a fe' T in the Chicago area, 
and a few small units -/ere scattered 1 throughout the country, chief Iv on 
the Pacific Coast.' The Union was unable to establish Union conditions in 
these factories outside of Hew York." (Some out of town factories were 
and are unionized but under different conditions than those of Hew York 
City). 

"The factories remaining in Hew York neve chiefly those making the 
high grade handbags which required the most skillful workers." 

"At the time the Code was being drafted, the industry was about 
equally divided between those manufacturers having contractual relations 
with the Union located in Few York, and those without Union conditions 
all of whom were located outside, of Hew York. Factories in Her York 
were paying first class workers (by Union Agreement) $35.75 a week, and 
second class workers $32.00 a '.reek. General help about $18.00 a week 
for a 44 hour week. Factories outside of Hew York Were paving their best 
workers about $20.00 to $22.00 a week and general help from $5.00 to $3.00 
a week for a 48 to 54 hour "eek." 

9811 



-17- 



"Bitter struggle resulted because of the efforts of the Unionized 
factories to establish in the Code a. classification of the workers ac- 
cording to their skill and the o-oeratior. s performed at wage scales ap- 
proximating those that were being paid in Union factories. Those manu- 
facturers not unionized, fought to prevent the clarification of the wor- 
kers and the establishing of wage scales in the Code above the minimum of 
$14.00, claiming that their workers were not skilled , that the system of 
work employed in their factories, .mown ac the "section system" (not per- 
mitted in a. Union Factor" - ) did not recuire cny skill; that new machinery 
and new methods revolutionized the manufacturing of ladies handbags, par- 
ticularly in factories making low price bags of cloth, (imitation leather) 
to retail at one dollar or lees. At this time 80;S of the manufacturers 
making these cheap begs ^ere located otLtside of Metropolitan New York." 

"At the tine the Code for the industry was adopted, the wage scales 
in the industry resembled somewhat a toboggan slide, going from $3 c -.75 a 
week (the minimum demanded by the Union for skilled workers) down to 
$6.00 a week paid in same outside factories." 

Meetings were so frecuent, discussion prolonged, and acrimonious, 
almost to the point of blows, that one wonders how those taking part 
found time to attend to their production and selling operations. 

Through the refusal of the Administration to '"rite into the Code the 
asked for classification or wage scales above the minimum, labor clauses 
were at last ironed out, but only to a degree, for there was inserted a 
provision, Article IV, Section 2, for "semi skilled", and a '"'age set fcrr 
them. This was stayed in the President's order of approval and became 
the subject matter of a later hearing, proving to be a constant thorn in 
every one's side. 

Having arrived at some semblance of peace, dissensions broke out 
anew over the set up of the Code Authority, the method of selection, and 
the division of membership, as between out of torn and New York. This 
was finally settled, although not to every one's satisfaction, and the 
Code Authority was final 1" set up as provided. 

Of the sponsoring organizations, two placed no restrictions upon 
membership and dues were not large. These two were the Associated Hand- 
bag Industries of America, Inc., New York, and the Midwest Handbag and 
Small Leather "Tares Association, Inc., Chicago. The membership of the 
third group, the Industrial Council of the Ladies Handbag Industry, New 
York was confined to manufacturers having contractual relations with the 
Union. Particulars of these three groups will be found in the succeeding 
paragraphs. 

2. Officers - Code Committees , Interested C-rou'os 

The officers of the various Industry groups who sponsored the Code 
were: - 

Associated Handbag Industries of America , Inc., Few York, N.Y. 

(Succeeding the Leather Soods Association.) : 

9811 



-18- 



Julius Michel President Maksik & Peldmen, Inc., 1T.Y. 

A. Mittenthal Chairman fi V. Pres. Elian & Mittenthal, N. Y. 

Samuel Goldsmith Treasurer Goldsmith Bros., N. Y. 

Morris Immerman Secretary Bagcraft Mfg. , Inc. 

Maurice S. Ilosesson Exec. Secretary Assoc. Handbag Industry of 

America, Inc. 

Incorporates June 14th, 1932 under the laws of the State of New York. 

Has membership of 100 concerns throughout the United States. 

Midwest Handbac and Small Leather T, r a:-es Association , Chicago, 111. 

President Harry Morris Morris Mann & 3eilly Inc., Chicago, 111. 

1st Vice Pres. !7m. a. Tanner Royal Leather Goods Co., St. Louis, Mo. 

2nd Vice Pres. Samuel Malow Crystal Leather Goods Co., Chicago, 111. 

Treasurer Ben. D. Levine Mirro Leather Goods Co., Chicago, 111. 

Secretary Edw. M. Luce 320V. Adams St., Chicago, 111. 

Approximate Membership 15. 

Industrial Council of the Leather Goods Mar.uf ac ture r s Inc. , Few York, N.Y. 

President Michael Bienen Bienen Davis Inc., New York 
Vice Pres. Samuel A. J. Rosenthal Rout Rosenthal Co., lew York 
Sec. & Treas. Milton J. Lefcort 
Approximate Membership 50. 

One other important Trade Association came into being during the 
first days of code writing. This was known as the National Association of 
Ladies Handbag Manufacturers (first known as Popular Priced Handbag Manu- 
facturers Association) . 

I quote the following letter to emphasize the position taken by this 
association, through its counsel, and to illustrate the feeling existing 
between the contending groups. 

SCHLESINGEH & OUTSET 

COUNSELLORS AT LAV/ 

270 Broadway 
New York City 

Se-ot ember 22, 1933 

James C. Morthy, Esc, 

Assistant Deputy Administrator, N. R. A. 
Department of Commerce Building 
Washington, D. C. 

Dear Sir: Rer Ladies Hand Bac Industry Code . 

In this connection ma3 r we bo permitted, to advise you that we represent 
9811 



-19- 



the National Association of Ladies Handbag Manufacturers (formerly Popu- 
lar Priced Handbag Manufacturers Association name changed September 11, 
1933) which has a present membership of forty among which are included 
practically all of the largest manufacturers in the industry. The mem- 
bership of this Association will be considerably augmented by the affilia- 
tion therewith of the Midwest Hand Bag & Snail Leather Wares Association, 
having a membership of twenty- two and to approve such affiliation a special 
meeting of the Eidwest Hand Sag & Small Leather 'Tares Association has been 
called for September 23rd, 1933, at Chicago and relative thereto the 
Secretary thereof under date of September 20, 1933, writes us - 

"I believe after that meeting, in fact I am almost sure, 
we can send you our formal acceptance of your propositions 
and have you enroll as a suosidia.r" r . " 

The present membership of the National Association of Ladies Hand- 
bag Manufacturers (exclusive of the Midwest Hand Bag & Small Leather Hares 
Association) is representative of the entire industry, controls a majority 
of production and employs a large majority of the employees engaged in the 
industry. Many of the members of this Association were formerlv members 
of the Associated Handbag Industries of America, Inc., the "submitting 
association, " and recently found it necessary to sever their relations 
therewith, because the interests of and the problems affecting the members 
of the Association we represent and those in control of the "submitting 
association" are conflicting if not diametrically opposed to each other. 

The purpose of this letter is to advise you, as we are informed, that 
the "submitting association" is not representative of the industry and 
that it is not authorize: to speak or act for the members of the Associa- 
tion we represent and to respectfully suggest that, in light of the infor- 
mation herein contained, it might be advisable to have its representative 
participate in the oreliminary hearing on September 28th. 

Very truly yours, 



SCHL3SI17GEH & KHINSKY 

By (Signed) I. E. Schlesinger 

rssriG 

Encs. 

The officers of the National Association of Ladi e s Handbag Hanuf a,c tur e r s 
were: - 

President Ira Sosenzweig 

Vice Pres. Morris Aarenau Aarenau and Holf Inc., Fall River, Mass. 

Treasurer Henry Meyers Meyers Mfg. Co., Norwalk, Connecticut. 

Secretary Ethel Nagel 



Approximate Membership 40. 



9811 



-20- 



This Association took exceotion to the Code as ore son ted and remained in 
opposition Ion/; after approval. 

The Midwestern Group and the small local Massachusetts Group (Haver- 
hill Ladies Ifenc.bag Association) were not active participants in these 
fights, in. fact were Trade Assxantions' hardly more than in name, onl~ r 
coming into being about this time. Of the last named Association, we 
have no record beyond mention here and there at the hearing and no par- 
ticulars are at present available. 

The following were the Committees formed: - 

For Associated Handba,? Industries of America , Inc . 

A. Mitt en thai, Chairman 

M. P.. Biennen 

H. Schoenfield 

Um Immerman 

M. S. Hosesson 

N. Greenbaum 

S. Ilutterperl 

I'. Magid 

S. ?.. Goldsmith 

C . Mo s s 

For Industrie,! CoTmcil of Leather Goods Manufacturing , Inc . 

I. Schwenholz 

M. Lefcort 
ivi. TTeinraan 
J. Michel 

For Midwest Har d.br -- gnu. Smrll L-eat k;,- '.."ares Association , Inc . 

Samuel Malow 
2d 1 ..'. M. Luce 

For National Association of Imitation and Leather Royalties 

(There is confusion in records as to correct, name of this 
Association, sometimes it is referred to as here given, 
sometimes as National Association of land Bag Manufacturers.) 

Hyman Bur stein 
Irving Meyers 
Murra~ r He snick 

Samuel H. Goldsmith 
Isidor E. Schlesinger 
Sol Mutterperl 

For Haverhill Beaded Bag Association 



Crest Scanni tiles 
9811 



-21- 



3. JRQ-i .SUBMISSION 0? FIRST DRAJT C0D3 TO PUBLIC H5ARINC 

1. 3rief Summary of Conferences and Negotia t ions 

Constant reference is found in the general files, Volume A and the 
transcript cf the first hearing as to conferences, proposed and held, 
Doth in the several months proceeding, and following the first hearing, 
but no record of these are to be found in the files. Neither is there 
an" record of the many conferences held by industry for I am told that 
because of the bitterness of the fighting it was not deemed politic to 
keep such. 

In the light of my own knowledge it is however not difficult to 
piece together the happenings of that time and to at least form an idea 
of the principal points at issiie. 

It was maintained by the major dissenting group (National Associa- 
tion of Ladies Handbag Manufacturers) that the sponsors of the first code 
draft submitted were not representative, therefore it followed, their 
views were not as sound and constructive as they should and might have 
been. This it was felt, was particular^ the case with respect to clas- 
sification of workers, which New York wanted, and representation on, and 
method of selection of the Code Authority. 

Naturally rational' s conclusions (see brief incorporated in trans- 
cript of Public Hearing, pages 258 to 263 inclusive) led to freouent con- 
ferences, correspondence and telegram:;, which last are to be found in the 
general files. In addition, Col. Lea's files, Volume A, show that meet- 
ings and correspondence were held with officials of the National Retail 
Dry Goods Association with respect to the discount end term provisions 
proposed by industry. A glance over the many communications received, 
gives an idea of who's who in the Department Store field, and definitely 
expresses unalterable opposition to any changes in terms over those in 
existence for some years. 

Here as in other industries it was a case of New York vs. the rest 
of the country, coupled, with a particularly bad labor situation intensi- 
fied by the 'migration movement. 

Both labor and. manufacturers were in the ore-depression days suffer- 
ing from too much financial fat, inability to think clearly, and refusal 
to consider and. find, the sensible approach to their problems. Labor, as 
represented by Union Officials then in power, refused to discipline their 
own people so that ran'- and file ran riot. In this connection it is in- 
teresting to note that, as is often the case it \7as a small thing that 
led to the first Few York manufacturer leaving the Metropolitan area. 
This manufacturer complained, to Union officials that one of his workmen 
had. soat in his face and called him unprintable names. The manufacturer 
na.turally expected, the offending workman would bo disciplined. Failing 
to get red.ress from the Union he came to the conclusion that he could no 
longer live in harmony with the Union and. decided to find factory accomo- 
dations outside the city limits, moving to Pennsylvania. Little by little 
industry left New York City, and. the depression setting in in full force 
the situation became* dangerous!;'' acute. 

9811 



-22- 



In the period immediatel" proceeding the Code, macs production came 
in and the average price for Sandbags had. fallen from $2.50 and 53.00 to 
$1.00 or less. During' that time, bavin. •- reached the "bottom of com-oetition 
based uoon labor, industry began to red to their products, gadgets of one 
sort or another, a character of bag accessories heretofore found only in 
the higher price ranges. Exhausting the range of gadgets in the domestic 
markets, there began a combing of foreign markets so that at the beginning 
of the Code era, industry Was in desperate straits, for obviously there 
must be an e'nd to such a Competitive race. 

Pre-code Conferences cjuickly developed that Few York manufacturers 
saw in the Code, an opportunity/ to at least' partially even up with out of 
torn industry by writing into the instrument, provisions for classifica- 
tion, etc. In conferences with the Administration it developed that al- 
though classification had been allowed in certain industries it had been 
declared as contrary to policy. (Exhibit J.) 

During this period labor itself was not idle and it too was insistent 
uoon classification and at the public hearing of Tecember 8, 1933 presented 
a comprehensive brief covering this. (See pages 50 to 99 transcript 
Public Hearing of that date.) ITaturally these arguments were resented hy 
manufacturers outside of the her York area, hence the fights. Summed uo, 
the main -ooir.ts at issue \7ere 30 hours against 40, classification -vs. non- 
classification, discounts and representation. Agraements were not reached 
ant? the proposed code went to public hearing and disputed points not even 
then settled. 



9811 



-2: 



C. • PUBLIC H EARINGS ON CODE 

1 . D ates: ma.ior -personnel: result s 

The only public hearing held took place on 
December 8th, 1933 at the Carlton Hotel, Washington, D. C. 
It was presided over "by Dr. Earl Dean Howard, Deputy Admin- 
istrator, who nad as advisors:- 

Hr. Max Berkowitz, Industrial Advisory Board 
Miss Rose Schneiderman & W. E. Bryann, Labor 

Advisory Board 
Mr. Fred Huhlein, Consumers Advisory Board 
Mr. J. P. Davis, Division of Research and_ Planning 
Mr. G. H. Barrenboim, Legal Division 

and the principal witnesses heard were:- 

Mr. A. Mittenthal, Associated Handbag Industries 

of America 
Mr. I. Scho'enholz, Industrial Council of Leather 

Goods Manufacturers . .. ' '.. 
Mr. E. M. Luce, Secretary, Midwestern Handbag 

and Small Leather Wares Association 
Mr. Isadore S. Schlesinger of Schlesinger and 

Krinsky, : 270 Broadway, New York, Counsel for 

and representing National Association of 

Imitation and Leather Novelties. 
Mr. C. A. Newton, representing Meeker & Co., 

Joplin, Mo. 
Mr. Irving C. Fox and Mr. Samuel W. Reyburn 

representing the National Retail Dry Goods 

Association 
Mr. Lewis. 1 Waldman, Counsel for and representing the 

International Pocketbook Workers Union 

Affiliated with A. F. of L. 
Mr. Maurice Magid, Associated Handbag Industries of 

America 
Mr. M. R. Bienen, Industrial Council of Leather 

Goods Manufacturers. 

Mr. Mittenthal of Associated Handbag Industries of America, 
the first witness heard stated that his association together with 
the two affiliated organizations, Industrial Council and Mid- 
western represented about 75$ of the entire industry. 

This figure was disputed however by -Mr. Schlesinger, ap- 
pearing for National Association of Imitation and Leather 
Novelties, basing his figures on the Census report of 1931. Later 
he incorporated in the record a brief covering this. (Pages 238 to 
263 transcript Public Hearing December 8, 1933). 



9811 



-24- 

The other witnesses were heard in about the order given and as 
the hea.ring progressed it became clear that the sharp division evidenced 
in pre-code conferences still existed among the manufacturers themselves, 
between manufacturers and labor respecting basic rages, classification 
homework and hours, further that industry as represented from the ^astern 
States fell into t'^o camps 'and that in their various meetings had not 
been able to find a common ground, and still further that the only major 
proposal upon which there was a meeting of minds, insofar as manufacturers 
were concerned, was that of the terms under which industry desired to 
sell goods. 

As stated in the foregoing chapter, labor wanted 30 hours specified, 
as against 40 hours proposed by and agreed to by manufacturers (see para- 
graph 2 page 55 transcript of public hearing, December 8, 1933). The 
argument presented by labor was that only by so doing could the unemployed 
workers be absorbed. Manufacturers on the other hand pointed out that the 
out of town manufacturers at least, accustomed to working 48 to 54 hours 
could not meet such a demand and live and were making quite a sacrifice 
as it was. Labor also insisted that home work be abolished. The principal 
group using Homeworkers, Beaded 3ag ranufacturer- , insisted th.it they could 
not operate without such workers. Labor insisted they must have classi- 
fication. Out of town industry refused to consider this and it was later 
ruled out by the Administration as contrary to policy laid down by the 
Policy Board. (Exhibit J.) 

Manufacturers particularly those of the East ^ere at odds among 
themselves over representation, since the out of town men felt that having 
the bulk of production they should have a majority on the new Code Authority. 
This was disputed by the Associated group, the principal sponsor of the 
code who insisted., that represented in the National's figures were a number 
of Associated members. Neither could agree upon this point. (See brief, 
pages 238 to 254 Transcript Public Hearing). 

There was also voiced by Mr. Newton, representing Meeker Co*, Joplin, 
Mo., an objection to the proposal covering learners or apprentices, and 
pointing out their need for a differential. (Page 27, Transcript Public 
Hearing, December 18, 1933) 

It was also brought sharply out that the retail world as represented 
by Messrs. Fox and Heyburn were opposed to any change in terms. These 
gentlemen gave the Administration to understand that the discounts at 
present in use had always obtained, should be retained, and the new terms 
would mean advanced prices to the consumer. On the other hand industry 
insisted that the present terms were of but recent origin, that depression 
had been largely responsible for them, and that for many years prior, terms 
had been substantially as proposed in the code. 

(See Exhibit H, which although proposed long after, states 
the "Selling Terms" case from the viewpoint of industry also 
Transcript of Hearing, pages 134-162. ) 

The other trade practice provisions were discussed but no serious 
irreconcilable differences developed. 

9811 



-25- 

The hearing closing at 5:35 p. ra. settled none of the major problems' 
presented, all being referred to conferences. 

D. FROM PUBLIC HEARING TO APPROVAL 

Eight days after the hearing, the following letter ' indicated th?t 
final drafting was to be plain sailing, for while it was admitted there 
were still one or two important matters in controversy, Mr. Mittenthal 
expressed the belief that all were nretty much in agreement. It is un- 
fortunate the modifications referred to in this letter cannat be found 
in the files, but the Administration's then proposed "set up" for the Code 
Authority is to be found on vage 6, part 7, Exhibit A.' 



Hew York, N. Y. 
December 16, 1933. 



IT. James Worthy, Deputy Administrator, 
National Recovery Administration, 
Commerce Building, 
Washington, D. C. 

Dear Mr. Worthy: - 

After a 'number of conferences had with the National Association of Leather 
Handbag Manufacturers, and other interested parties in our code, I find that 
we are agreed upon practically everything in the code as it was rewritten 
in your draft of December 12, with these few exceptions. 

We all urgently request modifications of the following articles, in order 
that they may be clarified and prevent the unscrupulous manufacturer from 
evading the fair trade practice rules. In most articles the addition or 
omraission of even a single word may make the entire trade practice rules 
innocuous, and by requesting these slight modifications, we are seeking to 
protect the interests of all the manufacturers against the chislers. 

I am enclosing a copy of these suggested modifications with a few comments 
setting forth the reasons for these. Of course, there is a great deal 
more than 1 could add to prove the necessity for these changes. 

There still remains the two main controversial matters that cannot be en- 
tirely agreed upon, namely the Code Authority, and the classification of 
basic rates*. 

I still fepl that the Code Authority as suggested by the administration is 
fair to all uarties concerned. It is true thflt the Associated Handbag 
Industries of America feels that it should have been accorded more re- 
presentation, however, they will accept the Code Authority as set up in 
your draft of December 12 as fair and equitable, and I see no reason why 
the National Association of Leather Handbag Manufacturers, should not do 
the same. 



9811 



-26^ 

The Industrial Council still clings to the ho^e that classification of 
basic rates can be included in the Code, particularly since the Millinery 
Code has just come out with ruch classifications. However, I "believe 
that if you ^ill again assure them that it cannot be done, they rill 
accept this as final-* 

I have 1 onmod that the National Association of Leather Handbag Manufac- 
turers, has objected very strenuously to the interpretation of the Metro- 
politan Area, and that they are requesting a change from thirty-five miles 
to fifteen miles from Columbus Circle. 

I think this could be accorded them without any serious objection on the 
part of the other groups. 

TTith the modifications granted and the controversial matters compromised, 
there is nothing really left in dispute and there is nothing further in 
the way of the Code being aToroved. 



Very truly yours, 



A. Mittenthal:AHJ 



Unfortunately those hopes were not altogether well founded for on 
December 28th, 1933 a telegram was sent to Mr. A. Mittenthal calling for 
a conference with the Division Administrator on the matter of selling terms 
and still later other wires sent calling for other conferences. See 
following. 

couisacE . 

JCW:G INDUSTRIAL RECOVERY 
4320 



DECE1.3ER 28, 1933 



MR. i.ilTTENTHAL . ... 

ASSOCIATED HANDBAG- INDUSTRIES OF AMERICA INC 
303 FIFTH AVENUE 
NET; YORK CITY 

IF CONVENIENT TO YOU TILL ARRANGE APPOINTMENT TITH WHITESIDE FOR 
TUESDAY NEXT T7ESK RE HANDBAG DISCOUNTS HAVE SMALL DELEGATION ONLY IN- 
CLUDING YOURSELF 3URX0WITZ AND PERHAPS Ol'E OTHER PERSON SEASONS GREETINGS 



JAMES C WORTHY 

ASSISTANT DEPUTY ADMINISTRATOR 

DIVISION FOUR 



9811 



-27- 
WESTERN UNION 



1933 DEC 29 PM 9 59 

NA 1284 21 EL - NEW YORK NY 29 

DE EARL DEAN HOWARD - 

DEPUTY ADMINISTRATOR NATIONAL RECOVERY 

ADMINISTRATION COMMERCE 3LDG WASH! DC 

WILL 3E IN WASHINGTON WEDNESDAY FOR APPOINTMENT *.7ITH ADMINISTRATOR 
WHITESIDE PLEASE TELEGRAPH HOUR OF APPOINTI!ENT BERKOWITZ SCHLESING 
AND MOSESSON WILL ATTEND = 

A MITTENTHAL 



COMMERCE 

JCW:G INDUSTRIAL RECOVERY 
4320 

CONFIRMATION SHEET 

THE NATIONAL RECOVERY ADMINISTRATION, COMMERCE BUILDING, SENT YOU A TELE- 
GRAM THIS DATE, OF WHICH THE FOLLOWING IS A CORRECT COPY: 



JANUARY 10, 1934 



IRA ROSENZWEIG PRESIDENT 
"NATIONAL ASSN LADIES HANDBAG MERS 
1182 BROADWAY 
NEW YORK CITY 

CONFERENCE ON HANDBAG CODE CALLED TEN AM I-RIDAY ROOM FORTYTHREE 
TWENTY DEPART! E: T T COMMERCE EXPECT TO iAXE FINAL DECISIONS REGARDING 
CONTENTS OF CODS IMPORTANT THAT YOU BE PRESENT WIRE REPLY 

JAMES C WORTHY 

ASSISTANT DEPUTY ADMINISTRATOR 

SAME AS ABOVE TO: 

Julius Michel, 501 7th Ave., N.Y.C. 
Michel R. Bienen, 307 Fifth Ave. , N.Y.C. 
Irving Schoenholz, 56 TTest 35th St., N.Y.C. 
Abraham Mittenthal, 1115 Broadway, N.Y.C. 
Morris Iramerman, 30 East 33rd St., N.Y.C. 
H. Burstein, 325 Fifth Ave,, N.Y.C. 
S. R. Goldsmith, 38 West 32nd St., N.Y.C. 

9811 



-28- 

L. S. "ettels, 303 Fifth Ave. , N.Y.C. 

' ilton Lefcort, 130 ""est 31st St., N.Y.C. 

'aurice Aarenau, 14 West "2nd St., N.Y.C. 

H. Margolin & Co., 1237 BroaxVay, N.Y.C. 

Sol :utterpeirl, 530 Fifth Ave., N.Y.C. 

George Meyers, 1133 Broadnay, N.Y.C. 

I. Schlesinger, 270 Broadway, N.Y.C. 

E. II. Luce, 320 Test Adams St., Chicago, 111. 

It will "be seen that with the exception of the first there is not any 
indication as to the particular phases of the code that were to be dis- 
cussed. 

Following these conferences it Decade known that a finished document 
had "been prenared and, was awaiting signature for immediately there came 
in a flood of protests, I quote a few only, taken from the files, for all 
are pretty much of the same tenor - opposition to representation, terms 
discounts and wages. 



POSTAL TELEGRAPH 

N.A 714 384 NL 5 Extra 1934 Feb 9 FT 7 42 

HK NEW YORK 1IY 9 

COLONEL ROBERT LEA 

DEPUTY ADMINISTRATOR OF INDUSTRY DEPT OP COLT! BLDC WASH DC 

RE CODE COVERING LADIES HANDBAG INDUSTRY THIS "IRE TO CONFIRM TELEPHONIC 
CONVERSATION OF TODAY STOP WE REPRESENT THE NATIONAL ASSOCIATION OF LADIES 
HANDBAG MANUFACTURERS STOP PAPERS ON FILE "TILL INDICATE MEMBERSHIP ETC OF 
THIS ASSOCIATION STOP WE UNDERSTAND CODE HAS BEEN DRAFTED BY DEPUTY AND 
ADVISORS AND IS ABOUT TO 3E SUBMITTED TO YOU FOR APPROVAL STOP SINCE 
SUBMISSION OF CODE TO COVER THIS INDUSTRY THIS ASSOCIATION HAS CONTENDED 
AND STILL CONTENDS THAT THE SPONSORS OF THE CODE ARE NOT TRULY REPRESENTATIVE ( 
OF INDUSTRY STOP THE MEMBERS OF THIS ASSOCIATION REPRESENT NOT LESS THAN 
HALF THE VCLUIZE OF BUSINESS DONE BY THE ENTIRE INDUSTRY AND EMPLOY 
CONSIDERABLY MORE THAN HALF OF ALL WORKERS ENGAGED THEREIN STOP THE ISSUE 
WITH RESPECT TO REPRESENTATION HAS BEEN TENDERED RIGHT ALONG AND DIRECTLY 
AT THE PUBLIC HEARING BUT HAS NEVER BEEN PASSED UPON AND WE BELIEVE NO 
ADEQUATE INVESTIGATION IN THAT DIRECTION HAS BEEN MADE STOP WE HAVE 
LEARNED BUT ONLY FROM THE PUBLIC PRESS THAT WITHIN THE LAST WEEK CONFERENCES 
HAVE BEEN HELD AT WASHINGTON RELATIVE TO THIS CODS ATTENDED ONLY BY PARTIES 
AND ASSOCIATIONS WHOSE INTERESTS ARE ADVERSE AND IN DIRECT CONFLICT WITH 
THOSE OF THE MEMBERS OF THIS ASSOCIATION STOP WE WERE NOT INVITED TO 
PARTICIPATE IN THESE CONFERENCES STOP THE EIGHTEEN DOLLAR OR FORTY- 
FIVE CENT PER HOUR MINIMUM WAGE PROVISIONS IN THE PROPOSED CODE REPRESENT 
THE DEMANDS OF NEW YORK MAIJUFA'CTUHERS AND THE INTERNATIONAL POCKETBOOK 
WORiJERS UNION AND WILL PROVE DESTRUCTIVE TO A LARGE NUMBER OF THIS 
ASSOCIATION WITH PLANTS LOCATED OUTSIDE jF THE NEW YORK CITY AREA STOP 
THESE WAGE PROVISIONS WERE ' INCORPORATED WITHOUT ANY APPROPRIATE SURVEY 
OR INVESTIGATION TO ASCERTAIN WHETHER OR 'NOT THEY ARE FAIR ANT) EQUITABLE 
TO THE OUT OF TOWN MANUFACTURERS AFFECTED THEREBY STOP THE CONTROL OF THE 
CODE AUTHORITY IS PLACED IN THE HANDS OF NEW YORK MANUFACTURERS AND THOSE 

9811 



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IN CONTRACTUAL RELATIONSHIP WITH INTERNATIONAL POCKETBOOK WORKERS UNION 
WHOSE INTERESTS SO FAR AS LABOR IS CONCERNED ARE IDENTICAL AND ADVERSE 
TO TIE OUT OP TOWN MANUFACTURERS STOP WE WANT TO GO ON RECORD AS OPPOSING 
THE EIGHTEEN DOLLAR OR FORTY-FIVE CENT PER HOUR MINIMUM WAGE PROVISIONS 
CONTAINED IN THE PROPOSED CODE AND THE PROPOSED CONSTITUTION OP THE CODE 
AUTHORITY AND ASK FOR FURTHER HEARING WITH RESPECT TO THE MATTERS COVERED 
BY THIS TELEGRAM 

SCHLESINGER & KRINSKY 270 BHOADWAY FEW YORK CITY 

DAY LETTER 



February 10, 1934 



Colonel Robert Lea 

Deputy Administrator of Industry 

Department of Commerce Building 

Washington, D. C. . . . 

Re Ladies Handbag Code STOP Our wire last night was based on 
telegram received from James C, Worthy Deputy Administrator STOP We 
have just received copy of latest proposed Code STOP In the previous pro- 
posed Code prepared by the Administration the Associated Handbag Industries 
of America -.Jnc was given a representation of three members on the Code 
Authority STOP The Industrial Council of America one and the National 
Association of Ladies Handbag Manufacturers three STOP Even to this ap- 
portionment we objected and. nor we find that rithout our consent without 
notice to us and without being heard, with respect thereto the proposed 
Code forwarded to us allots to the Associated Handbag Industries of America 
five representatives and to the Industrial Council of America two and to 
the Association that we represent also two although the members of this 
Association do at least one half the volume of business of the entire in- 
dustry and we employ more than one half the workers engaged STOP w e 
again ask that all definite action with respect to this Code be postponed 
until the members of the National Association of Ladies Handbag Manufac- 
turers have been afforded a further opportunity to be fully heard 

SCHLESINGER & KRINSKY 

Attorneys for National Association 

of Ladies Handbag Manufacturers 



9811 



-30- 

GOLDSMITH BROTHERS 

Manufacturers of Ladies' Hand Bags 
38-40 West 32nd Street 
New York City 



February 14, 1934. 



TTational Recovery Administration, 
Colonel Robert Lea, 
Deputy Administrator of Industry, 
Department of Commerce Building, 
Washington, D. C. 

Dear Colonel Lea; 

We wish to enter with you our protest against the Code of Fair 
Competition for the Ladies' Handbag Industry, as submitted to you in 
its present form, in view of the fact that the Code as written is benefi- 
cial to the certain few of the New York manufacturers. 

We base our orotest on the following, and which we ho-oe and have 
no doubt that in view of your fairness will give it every consideration: 

Statistics will confirm our contention that seventy nercent of the 
handbags manufactured in the United States are made outside of Ne^ York, 
and only a small portion of handbags are made in New York City, namely, 
the high style and high priced bags, where a few dollars a week more to 
an employee does not hurt the price of the unit in any way. The manu- 
facturers, who are in Few York must have skilled help with many years 
experience in order to manufacture their lines. Today, out-of-town 
manufacturers find it very difficult to compete with, - TeTO York manufac- 
turers making the same tyoe of merchandise, due to the increase in wages 
made by the out-of-town manufacturers, namely, about 60"o, which is made 
up in the shortening of hours and the minimum scale under which the NBA 
permits you to operate. 

We were obliged, in order to cooperate with the President's Emergency 
Measures, to advance our help who were receiving *8.00 and £9.00 a week 
to $12.0C per week, and those getting $12.00 per week and over were ad- 
vanced proportionately, as also their hours of labor shortened to conform 
with the M. R. A. thereby adding many additional help to our payroll. 

We estimate that the out-of-town manufacturers erroloy approximately 
10,00© workers whereas the New York manufacturers emnloy approximately 
2,000. 



9811 



-31- 

The out-of-town manufacturers must continually each new help 
the art of making hags, therehy incurring tremendous expense to the 
manufacturer, and the New York manufacturers, according to the code 
submitted to you, ask you to have us pay the same amount to our em- 
ployees, who, as stated above, must he taught the business from the 
beginning as against the New York Manufacturers 1 employees who have 
a number of years of experience, as the Union membership in Hew York 
has been closed many years for learners. 

We are employing in our -olant approximately five hundred • • 
people. Would it be, and would we be justified in shutting down 
our plant and the five hundred families supported thereby become 
public charges in order to satisfy a very small percentage of the 
industry? 

If the code is adopted in its present form, we will have 
no other alternative than to move our plant back to New York, which 
we might mention (is the sole object of the New York Union) thereby 
ruining the thousands of families dependent upon the out-of-town 
handbag manufacturers. 

To the cost of the out-of-town manufacturers' labor must be 
added the tremendous expense involved in breaking in new help. The 
tremendous .expense involved in the continual travel of their De- 
signing Staffs to the New York market. Trucking expenses add mat- 
erially to the cost of our manufacturing (and at the same time 
give employment to hundreds of neonle. Our office personnel is 
double that of our New York manufacturers due to the many details 
necessary for out-of-town manufacturers and which also adds hundreds 
of peorale to our payroll. And, the many other incidental items 
which add agreatly to the cost of manufacturing out of the New York 
market. 

In conclusion, we again wish to voice our protest of the Code 
in its present form, and as above stated, that if t he Code is signed 
as it is now written, bags will not be able to be manufactured out- 
of-town and manufacturers will be obliged, in order to profitably 
compete with New York manufacturers, move their plants back to New 
York, or else go out of business entirely, as the New York market 
does not have enough skilled labor to take care of the entire in- 
dustry and learners have not been permitted in the Union for sever- 
al years. 

Yours very truly 

GOLD SI! I TH BROTHERS 
MANUFACTURING- CO. , INC. 

LJBrFB 

P.S. - Whereas we now employ over five hundred in our plant, if 
we were to move back to New York we would only need approximately 
two hundred to produce the same amount of units. 



9811 



-32- 



WESTERN UNION 

1934 'FEB 15 PM 10 18 

CCI375 50' EL - WAUKESHA WIS 15 

COL ROBERT LEA - 

LEATHER DUPUTY ADMINISTRATOR WASH DC - 

VERY MUCH OPPOSED TO CONTROL OF HANDBAG INDUSTRY BEING 
INVESTED IN HAND OF ONLY UNIONIZED MANUFACTURERS IN 
NEW YORK STOP DUE TO GREAT DIFFERENCES IN CLASSES OF 
LABOR BETlffiEN NEW YORK AND MIDWEST A MOVE OF THIS KIND 
WOULD FORCE US TO DISCONTINUE OPERATION STOP WE PLEAD 
FOR CONSIDERATION OF THESE CONDITIONS- 

MASTERCRAFT LEATHER GOODS INC. 

POSTAL TELEGRAPH 

1934 MAR 21 PM 3 27 

WB48 DL 5 EXTRA-RK NEW YORK NY. 21 219P 
GEN HUGH S JOHNSON 
DEPT OF COMMERCE BLDG - 

RE LADIES HANDBAG CODE STOP THIS ASSOCIATION AT A 
MEETING LAST NIGHT ADOPTED A RESOLUTION EXPRESSING ITS 
DISAPPROVAL OF THE PROVISIONS 'OF THE CODE WITH RESPECT 
TO THE CODE AUTHORITY STOP IT IS THE OPINION OF THIS 
ASSOCIATION THAT THE MATTER OF REPRESENTATION OF THE 
CODE AUTHORITY HAS NOT BEEN DISPOSED OF OF AN-DQUlTABLE 
BASIS AND THAT THE QUESTION AS TO ".fflETHER THE' SPONSORS ARE 

TRULY REPRESENTATIVE OF THE INDUSTRY HAS NEVER BEEN ( 

ADEQUATELY INVESTIGATED TO JUSTIFY THE CODE PROVISIONS 
STOP WE HAVE CONTENDED SINCE THE , SUBMISSION OF TEE CODE THAT 
THE SPONSORS ARE NOT REPRESENTATIVE OF THE INDUSTRY 
AS THE PAPERS ON FILE WILL INDICATE STOP IT IS 
OUR WISH TO COOPERATE WISH THE ADMINISTRATION BUT WE 
FEEL THAT NEITHER THE SPIRIT NOR THE LETTER OF THE RE- 
COVERY ACT HAS BEEN FOLLOWED IN CONNECTION WITH THE DES- 
IGNATION OF THE CODE AUTHORITY AND RESPECTFULLY ASK 
FOR AN IMMEDIATE HEARING OF THIS MATTER AT '..'HICH ALL 
INTERESTED PARTIES MAY SUBMIT FACTS AND FIGURES PRIOR TO 
THE EFFECTIVE DATE OF THE CODE - 

THE NATIONAL ASSOCIATION OF LADIES HANDBAG MANUFACTURERS 
270 BROADWAY NEW YORK CITY. 



9811 



-33- 
NIGHT LETTER 



February 8, 1934 



Miss Frances II. Robinson 
c/o General Hugh S. Johnson 
Department of Coranerce Building 
Washington, D.C. 

AS FORMER LIEUTENANT COLONEL ACL UNDER MCCAIN AND HARRIS 
I RESPECTFULLY REQUEST THE FOLLOWING- MESSAGE BE DELIVERED 
WITHOUT DELAY TO GENERAL JOHNSON QUOTE RETAILERS CAN NOT 
KEEP PRICES DOWN ON LADIES HANDBAGS AS YOU BESEECHED 
THEM AT OUR CONVENTION IF YOU UNWITTINGLY CONDONE A 
NEEDLESS HIDDEN PRICE INCREASE 3Y APPROVING A CODE WHICH 
IS INTENDED TO EXACT A PROFIT OF TWO MILLION DOLLARS FROM 
CONSUMERS IN A FORTY MILLION VOLUME INDUSTRY THROUGH A 
REDUCTION IN THE PREVAILING CASH DISCOUNT OF EIGHT 
PERCENT TO THREE PERCENT SINCE THE CODE PROPONENTS HAVE 
NOT AGREED TO A COMPENSATING REDUCTION IN WHOLESALE PRICES 
OF THEIR PRODUCT STOP IF CODE MUST BE APPROVED EECOMIEND 
A STAY OF DISCOUNT PROVISION UNTIL COMMITTEE OF PROMINENT 
RETAILERS CONSISTING OF MESSRS ROTHSCHILD STRAUS RSYBURN 
MITTEN PRIDDAY AND OTHERS CAN PRESENT TO YOU OR YOUR 
APPOINTEE FACTS THAT WE BELIEVE WILL' FULLY JUSTIFY OUR 
OPPOSITION TO PRESENT LOW DISCOUNT PROVISION STOP 
WHITESIDES RECENT INTERMEDIATE REPORT TO YOU ON CAUSES 
OF NEEDLESS RETAIL PRICE INCREASES MENTIONS REDUCTION OF 
PREVAILING CASH DISCOUNTS AS ONE OF THE IMPORTANT FACTORS 
UNQUOTE 



P. J. Reilly 

Member, Retailers* Protective Committee 

National Retail Dry Goods Association 



February 12 , 1934 

Mr. Irving C. Fox 

National Retail Dry Goods Association 

225 West 34th Street 

New York, N.Y. 

Dear Mr. Fox: 

This letter is in reply to yours of February 7, to General 
Hugh S. Johnson. 

The Code for the Ladies Handbag Industry has already 
been recommended by me to the Administrator for approval. 

As you already know, at the time of the Hearing, provis- 
ions standardizing the discount at 3/10 EOM received very 
thorough consideration. 



9811 



-34- 



Moreover, a joint committee of manufacturers and 
retailers under the chairmanship of Mr. Reyburn was 
appointed but unfortunately they were unable to come to 
an agreement. 

In order to break a deadlock which had existed for 
several weeks, I authorized the Deputy to proceed in 
drafting a Code which would be satisfactory to the manu- 
facturers and which would contain the discount provision 
of 3/10 EOM. 

The action taken in the drafting of this Code seemed 
necessary if they were to have a Code at all. 



Yours very truly 

A. D. Whiteside, 
Division Administrator. 



ING3ER & COMPANY 

liAMJFACTUREES OP 

FABRIC HAND SAGS 

1307-09-11 Market Street 

Philadelphia, Pa. 

February 12, 1934 

National Recovery Administration, 
Colonel Robert Lea, 
Deputy, Administrator of Industry, 
Department of Commerce Building, 
Washington, D.C. 

Dear Colonel Lea: 

We received unofficial information that the Government 
is about to present a Code for the Ladies' Handbag Industry, 
in which there will be an $18.00 minimum. We wish to : 
protest against the inclusion of this paragraph in the Code 
for the following reason, which we believe applies to every 
manufacturer outside of New York City: 

AH manufacturers, outside of New York, are handicapped 
in competing with the New York manufacturers. To begin 
with, we do not have the skilled help that they have. Most 
all mechanics in New York have oeen in this Industry at least 
five or six years. The main reason being that the International 

9811 



-35- 



Pocketbook Union, with whom the New York Manufacturers are 
in contraction, does not permit them to take on any new 
help. For the last few years, there has been an over 
supply of help in this trade, due to the depression. Be- 
sides that, we are compelled to "buy our goods in New York, as 
that is the market place, and maintain an office in New York 
for the sale of goods, as "buyers will not go outside of New 
York to purchase. To maintain a New York office, and ship 
everything to New York City and East of New York prepaid to 
New York, also entails an expense. Coupling this with the 
average out of town help, which is usually not as skilled as 
New York, we are at a disadvantage. 

Besides, New York City has what is known as a Clearing 
House for workers. When they need ten extra framers for 
a day, they can phone to the local office, and this is done 
for any other department. Whereas when they take help out 
of town, and lay them off when they don't need them, they 
thereby stand a chance of losing them, because they usually 
drift into another trade. It therefore means that by the 
time we weed additional help, we have to start training 
them again. 

To avoid this, we try to keep them on. If a frame r 
has no work, we give him something else to do, and do 
likewise in any other department. This is how we manage 
to keep them, although there is a loss in doing so. 

For example, this is what happened to our Company: 
During the latter part of August, and the early part of 
September, we had a strike, when we brought in some new 
people, paying them the minimum wage. They have only been 
in our employ now for about six months. The National 
Labor Board, who was instrumental in settling the strike, 
asked us to make all employees back, which we did. Sufficient 
proof can be furnished that we are not discriminating, and are 
dividing the work as evenly as possible between the exper- 
ienced and inexperienced help. We believe this is what the 
Government wants. To keep everybody busy instead of a full 
week to some and nothing to others. 

From the above facts, you can readily understand that 
if an $18.00 minimum is put into the Code, we will probably 
be forced to shut down, or else eliminate all inexperienced 
workers. We know the Government does not have this purpose 
in mind, as it would mean so many more people to resort to 
charity. Therefore, we protest against the insertion of this 
clause in the Code, and as mentioned before, we believe that 
if it should be enforced, we would have to close the plant 
and move to Nev; York, where it will be possible to do 
business under the Code, 

Now what is to happen to the people in Philadelphia? 
Our company is employing about two hundred to two hundred and 

9811 



-36- 

ten people, and the rest of the Industry in Philadelphia is employing 
about one hundred and seventy-five. Considering the families dependent 
on these People's wages, it would necessitate about twelve hundred 
additional people going to the Relief Board, 

We are awaiting advice whether or not you will have a meeting in 
Washington on Wednesday or Thursday of this week. If so, we expect 
to he there to lodge our protest in person, •■ 

We hope it will hot he necessary to put this Industry in Philadelphia 
out of business. 

Yours very truly, 

INGBER & COMPANY- 

(Signed) D. A, INGBER, President 

WESTERN UNION 

(02) 

KA 423 101 NL 1 EXTRA - JOPLIN MO 14 

GENERAL HUGH S. JOHNSON - ■ 

NRA ADMINISTRATOR WASH D C - 

THE LADIES HAND BAG CODE RECENTLY PLACED IN YOUR HANDS TOR APPROVAL 
IS VERY UNFAIR TO US AS A SMALL TOWN MANUFACTURER IT CONTAINS NO WAGE 
DIFFERENTIAL AND LITTLE CONSIDERATION FOR 'THE ACTUAL CONDITIONS SURROUNDING 
US AS AN ISOLATED MANUFACTURER WONT YOU BEFORE DECIDING ON THIS CODS PLEASE 
REVIEW OUR BRIEFS AND CORRESPONDENCE IN TEE FILES OF DR. HOWARD- AND MR J C 
WORTHY ASSISTANT DEPUTY ADMINISTRATOR WE EMPLOY ONE HUNDRED FIFTY TO THREE 
HUNDRED PEOPLE WHO WILL BE WITHOUT EMPLOYMENT IF WE ARE FORCED OUT OF 
BUSINESS WHICH IS ALMOST SURE IF CODE AS NOW WRITTEN IS PUT THROUGH. 

THE MEEKER COMPANY INC 

C MEEKER PRES ■ 

WESTERN UNION 

VP 138 5 1 XU - PV NET? YORK NY 14 526P 

HUGH S JOHNSON, ADMINISTRATOR 

CARE OF MISS ROBINSON DEPT OF COMMERCE 
COREY MEEKER ONE OF OUR MISSOURI MANUFACTURERS WILL BE GREATLY' INJURED BY 
NO WAGE DIFFERENTIAL HAND BAG CODE HE HAS SUBMITTED BRIEF TO HOWARD BUT 
HAS NO WORD REGARDING IT .STOP APPRECIATE GREATLY IF YOU WILL HAVE SOMEONE 
WIRE ME LAMBERT COMPANY TWO FIFTY PARK AVENUE NEW YORK WHAT STEPS CAN BE 
TAKEN - 

ROBERT L. LUND' (03) 
9811 



-37- 
IE STEM UNION 

1934 FEB 15 PM 6 11 

Q3 604 135 NL 5 EXTRA - MIAMI FLA 15 
COLONEL ROBERT LEA DEPUTY ADMINISTRATOR INDUSTRY- 
WASH D C - 

INFORMATION LEADS US TO BELIEVE FOURTEEN DOLLAR MINIMUM WAGE FOR IMITATION 
LEATHER WORKERS EMINENT STOP WE ARE OPPOSED TO THAT MINIMUM AS IT MEANS 
IMMEDIATE CLOSING OF OUR PLANT EMPLOYING APPROXIMATELY HUNDRED PEOPLE STOP 
NINETY PERCENT OUR WORKERS INEXPERIENCED AND IF THIS CODE IS ADOPTED IT WILL 
POSTIVELY THROW THEM ALL OUT OF WORK IN FACT OUR DIRECTORS HAVE SERIOUSLY 
CONSIDERED CLOSING THE PLANT AS WE CANNOT MANUFACTURE OUR MERCHANDISE 
ON PROFITABLE BASIS UNDER PRESENT NRA CODE STOP EMPLOYEES WORKING IN 
OUR PLANT ARE WELL ABLE TO SUSTAIN THEM SELVES AND ARE TREMENDOUSLY THANKFUL 
FOR OPPORTUNITY TO 3E ABLE TO DO SO STOP PRESENT CODE MAY AND ADOPTION 
OF FOURTEEN DOLLAR MINIMUM WILL MASE IT CONCLUSIVELY NECESSARY FOR OUR 
PLANT TO CLOSE AND MANY OTHERS THROUGHOUT THE COUNTRY LOCATED GEOGRAPH- 
ICALLY SIMILAR - 

HARRY I MAGID VICE PRES STYLE CRAFT BAG CO INC 

HERZ MP KORY 

Makers of 

LITTLELADY CHILDREN'S & MISSES' BAGS 

230 Pine Street 

WILLIAMSFORT, PA 
February 16, 1934 

Colonel Robert Lea 

Dear Sir 

We have just "been informed that the ladies handbag code contains 
a minimum wage proposal of 18 per week and wish to say that if same is 
adopted will necessitate our removal to New York City, as we would be 
unable to compete, considering all other disadvantages and extra ex- 
penses. 

Yours resp. 



HERZ AND COMPANY 



9811 



-38- 



January 3, 1934 Deputy Earl Dean Howard writing the following 
memorandum to Division Administrator A. D. Whiteside was evidently 
inclined to a^ree with two of his advisors that the majority faction 
should meet with the Administrator and write a Code based upon the 
Division Administrator' s ultimatum viz: 

A wage minimum not to exceed ($18) eighteen dollars per week and a 
discount provision of 3?, 

1-3-34- 



Mr. A. D. Whiteside 

Earl Dear. Howard 

Messrs. Eillraan and Burlrowitz, Labor and Industrial 
Advisers, respective!-, on the Handbag Code have petitioned 
me in the matter of the deadlock on that code. 

They are convinced that the attempt bo get an agree- 
ment between the two factions in the industry has entirely 
failed since the last proposition to arbitrate their 
differences has been refused by the minority. 

They therefore rccom ie.:d that we authorize the major- 
ity faction, consisting of at least seventy-five per cent 
of the industry, to meet with the Deputy and .advisers and 
formulate a code on the basis of your, ultimatum co them, 
namely: two wa,:e minima not to exceed eighteen dollars 
per week" and discount irovision of three per cent. 

Mr. Hillman is not satisfies with the wage and hour 
provisions of the code submitted by the najority, but there 
is no doubt that these differences can be reconciled if we 
hold the conference which they recommend. This would involve 
a decision on your part to approve a code against which there 
was a minority o-riosition of probably twenty-five per cent. 

Earl Dean Howard 
Denuty Administrator 

On this memorandum are to be found question marks against* 
the figures a_uoted in the second line of third nara^raph and the 
last two lines of the 1; st para v ,:-a h. At the bottom is also a penciled OK 



-39- 

presumably made by the Division Administrator, A. D. "'."hiteside, and 
in vie^ of the conflicting claims made by the Trade Association 
one can well understand his doubt of accuracy of statements. 

All of that month and through February and March, the battle 
raged and sporadic references are to be found in the general files 
to neetings with the Division Administrator, the Deputy, the re- 
presentatives of the Labor Advisory Board and Colonel Lea.. Fol- 
lowing what appeared to have been the rule, insofar as this Code 
was concerned, no record was made of these conferences but from want 
I recall it seemed as if each faction was determined to rule or 
ruin, and could not or would not agree on the disputed points. 

A comparison of the draft submitted at the hearing (see pages 
270 to 285 transcript of Public Hearing) with the approved code 
gives light .upon what must have been the subject matter of the 
various meetings. I auote in the following the major points at 
i s sue : 

Proposed Code: Article II - Definitions not sufficiently 
clear, and without reservation, all em- 
bracing. 

Approved Code: Article II - Definition clarified more specific. 

Proposed Code: Article III - 40 hours in any one week and 
not in excess of 8 in any 24 hour period 
for factory and office help. 

Approved Code: Article III - 40 hours "oer week except that shipping, 
clerical or office forces were to average 48 hours 
over a monthly period. 

Proposed Code: Article IV - 35^ per hour for greater New 
York, 30<£ outside New York area. 

Approved Code: Article IV - A flat 35<£ rate per hour. 

Prono.sed Code: Semi-skilled not provided for. 

Approved Code: Provides for semi-skilled at 45d per hour ra.te. 
(Stayed in order of approval) 

Proposed Code: Leaners to be paid not less than 8C C £ of 
minimum wages and must not exceed 15$ of 
total number of employees. 

Approved Code: The Administrator may under exceptional circumstan- 
ces permit employment of learners. 

Proposed Code: Classification None. 

Approved Code: Section 6 provides that upon recommendation by the 

Code Authority and after full study the Administrator 

9811 



-40- 

may establish basic rates Tor the more 
skilled classes of employees. 

Proposed Code: Article VI - Administration provides 
Code Authority of eleven (ll) to be 
selected by various associations. 

Approved Code: Article VI - Administration provides eleven 

(ll) 'selected from industry: 



5 by Associated 

2 by National Association 

2 by Industrial Council 

1 by Midwest Association 

l..by' Pacif ic. Cos Tt: Manufacturers 

1 by Labor Advisory Board. 



Trade Practice Provisions were essentially the same. 

It will be noted that the wage provisions approved were a com- 
promise and as already stated became a fester spot and provocative of 
great dissension and widened the rift between labor and manufacturer. 

It will also be noted that representation provided in Article 
VI of approved code is auite different from the one contained in draft 
used at the public hearing and revised immediately thereafter (Exhibit 
A, part 7, page 6; part 8, page 4.) 

The Code was approved by the various Boards without comment 
except that of Research and Planning. Mr. James P. Davis of that 
Board pointed out that since the establishment of classified wage 
scales under codes is contrary to Administration policy it would seem 
wise to eliminate this provision. 

He further points out that the discount provision might be the 
cause of much criticism unless it conforms closely with the well es- 
tablished practice of the industry. • 

(See Exhibit E paragraph "Comments Section 2", Section 12) 

It was forwarded by Deputy Earl Dean Howard March 5, 1934 
to the Administrator for his approval. 

3. Date of Approval 

The Code was approved March 14, 1934 under Admin- 
istrative Order 332-1 and became effective under Article 
X;il of the Code on the second Monday after approval by 
tne President. 

4. Conditions in Order of Approval: Industry Reaction 

The Order of Approval provided: 

"1. That Section 2 of Article IV be stayed until 

9811 



-41- 



S uch tine as the Code Authority shall pr .ant to 
the Administrator a definition of the term 'semi- 
skilled employee', which received the -approval of 
the Administrator." 

" ■ The i** subjects, semi-skilled an del *%££"££? 

treated in the Code as separate and distinct matters, semi 
skilled in Section 2 and classification in Section 6 of 
Article IV approved code, are in effect part and parcel of 
each other. ■ 

There is no documentary evidence in the files f^ 

, r, *.**„ o n-F irtirle'IV was written into tne 
indicates when Section 2 of Article iv c.s, b _ 

■ ass tt£^&^*?£FZr 

her 8, 1933.) 

However in the drafts of November and December there 
appears a .revision for basic wages See Exhibit A, part 5. 
paragraph 5, page 3; part 6 .paragraph 5 page 3 part , 
paragraph 5, page 3; part 8, paragraph 5, page 3, 

Since labor was so insistent that classification be 
included in the wage provisions (See Transcript *«« 
inciuaea in b 61-65) and since the non- 

Hearing December 8 1933 pages b , ^ 

worker s e a/irrne°L^on agreements follow^ 

lamination of Uniop Agreements contained - ^ -e A and 
a reference to the statement of the Code Auth or ity La bor 
member dealing with this subject Se J,^ 1 * ^ & ^ r ~ 
discloses that the term ""mi-skilled" does not appear t 
have been used in the industry but instead shows the use o 
tSe term "Second class helpers", it is reasonable t sup 
pose that the Administration injected * h " c ^£ e a * n te 
promise measure, providing however that ■ the ^°^ S ^ t _ 
stayed until the Code Authority should present an accept 
able definition. 

To support this conclusion is a statement by Code 
Director Hit tenths! made to the writer September 11th, 
1935 that since industry could not agree upon classifica 
tion - New York wanting and out-of-town opposed toi»U 
■ elusion, the subject was referred f ^ll^Z'orT 
D. Howard, to Mr. Sidney Hillman of the Labor Advi ory 
Board. He told manufacturers, so the Director sxar, , 
he offered this clause and industry had better accede to 
' • it or suff er a worse fate by having a code imposed upon 
them by the Administrator. 

The Director further states that Colonel Lea opposed 



9811 



-42- 

its inclusion on the ground that such a clause could not 
be defined, satisfactorily at least, and would lead to 
endless trouble. Colonel Lea was eventually won over hence 
it found nlace in the wage provisions.* 

Could ones foresight "been as good as hindsight, the 
provision never would have been made for it led, as stated 
in the t>revious chapter, to endless discussion and friction 
between the manufacturers themselves, and made wider the 
existing rift between labor and industry. 

It was and is now my firm belief that it is impossible 
to justly determine where the line should fall as between 
skilled and semi-skilled. 

Vnen months after it was made the subject of public 
hearings J u ne to July 1934, (See Transcript of such), the 
Assistant Deputy David Barr and the Division Administrator 
Sol Rosenblatt finding that no one could agree, drew an 
order setting up a commission to stud:/ the industry (the 
expense to be borne by industry) and make a finding. (See 
Exhibit K, pages 22 to 25). Since industry would not con- 
sent this order was however never consummated. 

Proposals were then made by the Administrator to 
vacate the stay in the order of approval and to amend the 
section ~oy deleting the term "semi-skilled" and the words 
"made of any materials Other than imitation leather". 

On this the ooint of legality was raised by the Deputy, 
Colonel Harry Berry, to whom the code was transferred in 
August 1934, and J. G. Latimer, Division Counsel, rendered 
an oninion (see Exhibit L) stating that, such could not be 
imposed over the objection of a majority of industry. 

Colonel Berry and his Assistant, Mr. Leigh Ore, 
Colonel Walter Ilangun succeeding Colonel Berry and his 
Assistant, Mr. Dana Hill, made endless effort in the 
succeeding ten months to settle matt,ers but without 
success and there it rested when the curtain was rung down. 

The order of approval also contained the following 
provision: ( Paragraph 4 - Order of AuDroval Code 332) 

"2. That, in addition to other members of the Code 
Authority, there may be appointed by the Administrator 
< or .elected by such method as he may prescribe, in his 
discretion, not more than three additional members with 
voting privilege' to be chosen from members of the In- 
dustry who are not, in the opinion of the Administrator, 
adequately represented on the Code Authority." 

Industry itself having been unable to agree unon the 
constituion of a Code Authority, the Administrator found 



9811 



-43- 



it necessary to write one that in his judgment \yould meet 
the needs of the case. However, it is evident fearing it 
might later he found in a disclosure of further data that 
his conclusions were not 100$ correct the provision stated 
ahove was written in the order. I think this was wise for 
it later "Droved of value in the first steps taken toward 
re-uniting this industry. 

Volumes A and 3 and General Files are filled with 
petitions against and protests from Members of Industry, 
Chambers of Commerce, Labor Unions, Retail Stores and Trade 
Associations, not to forget lawyers that ™ere sent in dur- 
ing the months of October, November and December, 193-3 and 
January and February, 1934. 

The -orotests fall into four major grouos, objections 
to Discounts - Labor - Classification, - lack of wage dif- 
ferentials, - representation. 

Apparently almost every one was exhausted by the 
approval date for but eight protestants came forward under 
Executive Order 6205 B, and these were heard in public 
hearing May 7, 1934. The following are the names: 

"- Hudson Leather Goods Inc. , Nyack, New York 
G-. R, Godfrey Company, Gardner, Massachusetts 
Paragon Novelty Bag Company, Inc. , Newburgh, New York 
Uneeda Belt Company, Newburgh, New York 
Newburgh Handbag Company, Newburgh, New York 
Licht & Kaplan Inc. , Newburgh, New York 
Strand Leather Goods Company, Inc. , New York City 
Virginia Art Goods Studios Inc. , Lynchburg, Virginia 

There was doubt as to the validity of the last named 
protest, Virginia. Art, but Division Administrator Rosenblatt 
allowed them to be included in the public hearing held May 7, 
1934 before Assistant Deputy Worthy. (See Transcript Public 
Hearing and with reference to action upon Virginia Art see 
page 85 of same. Also see Appendix M for digest of Protests.) 

These protests were disellowed in Orc'.ers - Nos. 332 - 4 
5-6-7 with the exception of Vir ; inia Art which wan appar- 
ently left in abeyance ant- of this I shall treat later. 



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-44- 



COSE AlU.IlvISTEATION 



. . Organization 
Personnel 
Field Organization 

The Code Authority as a governing body 
, Budgets 
. . Effect on Industry 



9811 



III. Code Administration 

A. General Preliminary Discussion 

Reading the foregoing chapters it was obviously difficult to 
launch the new governing body, indeed it seemd for a time doubtful 
if an organization meeting could be held. However, the first official 
meeting was held, April 3rd, 1934. (See copy of telegram dated April 7, 
1934, Exhibit 10 Ferusal of the minutes of that meeting (General Files) 
indicate that tvo prior meetings were held March 23rd and !arch 29th, 1934. 

As was to be expected two distinct camps were evident, out of town 
manufacturers sitting on one side of the Council table, Few York placed 
opposite. That custom was followed until peace was declared in June 1934. 

Labor representatives not having been appointed were not present. 

The first business was that of election of officers and the 
following were elected, remaining in office until exniration. 

H. Schoenfeld - Chairman 

Sol Ivlutterpel - Vice Chairman 

George Meyers - Treasurer 

I. Schoenholz - Secretary 

Following, the Chairman and Code Directors (these last two in 
number, then not officially appointed although agreed to by the Board) 
were authorized to name committees to immediately consider the 
important subject of: 

Defining semi-skilled pursuant to Article IV, Section 2, 
Report on Handicapped persons pursuant to Article IV, 

Section 7 (e), 
Provide Minimum Standards pursuant to Article V, 

Section 6, 
To study question of Homework pursuant to Article V, 

Section 10, 
To draw ut> Contractors agreement pursuant to Article V, 

Section 12, 
To draw up Constitution and By-Laws pursuant to Article VI, 

Section 8 (b), 
To provide coordination with related Codes pursuant 

to Article VI, Section 8 (e), 
Pl^nring and lair Trade Fractice pursuant to Article 

Vi, Section 8 (g), 
To draw up Uniform Cost System pursuant to Article VI, 

Section 6 (i), 
To provide regulations of Style Firacy pursuant to 

Article VI, Section 8 (j), 
To draw up Label Regulations pursuant to Article VII, 
To draw up Regulations of Selling Below Cost pursuant 

to Article VIII, Section 14, 
Finance and Budget. 

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This was a fairly comprehensive committee set up and later minutes 
show that on the whole, appointed members took their work seriously, 
approached problems earnestly and intelligently, not sparing themselves 
or their time. Oft times they worked long and late, willingly giving 
up Saturdays arid holidays, and the Administration member being present 
at many of these Committee meetings cnn speak with knowledge as to 
proceedings. 

If we dwell upon this matter unduly it is that, although perhaps 
unwittingly, the Division Administrator was unjust, in the charges 
made by him at a -public hearing held June 7th, 1934. He at that time 
took occasion to openly rebuke the industry for lack oi diligence and 
for not functioning as well, as capably , as efficiently and as intel- 
ligently as it could (see Transcript Public Hearing June 7th, 1934, 
pages 2 and 3). 

These remarks had far reaching repercussions for the Code Authority 
keenly felt their injustice and deduced that the Administrator and 
his Assistant . Deputy were irrevocably committed to labor regardless 
of the verities, and. were not to be trusted. Thus was still more 
intensified the feeling between labor and manufacturer, and the Ad- 
ministration's problem in attempting to settle highly controversial 
matters made more difficult. 

At this first official Code Authority meeting it w^s decided that 
a meeting of industry should be called so that it might look upon 
its new Board and I was asked to be present and explain to industry 
just what the Code, if used properly and conscientiouslv, spelled for 
them. 



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■47- 



SOL MUTTJEEPJaili, INC. 
Manufacturers of 

PAHCT LEATHER GOODS 
330 Fifth Avenue 
Few York 



April 12th, 1934. 



Mr. O.Tw, Fearson 
New York City- 
Dear Mr. Fearsor: 

This is a reminder that in youi address to the nanuf rcturers this 
evening, you do not overlook to emphasize strongly the absolute nec- 
essity of adhering strictly to the code in order to derive the benefits 
that it affords to everyone in the industry. 

I suggest that you plead with them for their own interest to put a 
stop immediately to the t>rice war started since our code was signed. 
This price-cutting now is worse than ever "before in the history of 
our industry, and that, on top of higher wages and shorter hours. Such 
action on the part of some unscrupulous manufacturers kills tne entire 
morale of the industry and defeats the very purpose of the Code. 

Urger every one of them to have a little patience and courage until 
the Code is put into operation and with the assistance and cooperation 
of all concerned, we will all get the benefit that the Code and the 
entire Recovery Act offers. 

Ask them not to weaken nor falter, but stand together like men who 
have a -perfect right and just claim to a legitimate and honorable exist- 
ence in their business. 

By doing this we will gain the respect of those we come in contact with 
in our daily business dealings, and meet with much less resistance than 
we do now, P nd at the same time eliminate the abuses that are heaped 
upon us when we lack unity between ourselves and mistrust each other 
with nc good end to anyone, either to the manufacturer, retailer,, 
consumer or worker. 

Sincerely yours, 

/s/ Sol ivkitterperl. 
9811 



-48- 



This I did and one of the largest attendances known was had at the 
wcAlpine Hotel, Few York, manufacturers coining in iroa all parts of 
the country. This meeting '-as definitely the first step in consolidating 
the warring elements and payed a part in the peace pact signed some 
time later. 

The effect of the new code's "Terms" provision was brought out at 
both the Code Authority meeting and the later one of Industry, and it 
developed that p Hetail Buyers strike was threatened if recession from 
the Codes Terms fas not made. (See Exhibit N. Section dated April 7.) 

As the weeks passed feelings ran still higher, the old bugaboo 
"Representation", always to the fort, preventing to a degree a sane 
approach to problems from time to time- presentedi In May I found it 
necessary to halt a Code Authority meeting as such, and tackle the 
questions underlying the representation problems, (see Exhibit N- Section 
dated May ?5) and a few weeks later decision was lrde to unite all 
trade associations into one. 

Criticisr.i of this move "as mare by labor ^s being designed to 
better fight the moot-semi-skilled-shorter hour pnd classification 
problems, losing si£"ht of thi fret that the manufacturers' side of 
industry had still other battles facing them and needed unity if they 
'"ere to rehabilitate themselves. 

The Code Authority selected and later elected two former members 
of their o<-n industry to head up the Code Authority machine. 'These 
two men were unusu«llv ""ell equipped for their work, for in addition 
to having a first hand knowledge of processes and materials used, an 
understanding of style, all important to an industry of this character, 
an appreciation of the difficult cosition the industry was in, and 
knowing all the tricks of the trade, had a tact, a sympathy with and 
understanding of the aanuiacturers sake-u^ that was to stand them in 
good stead in the troublous months ahead. That their pccomolisnments 
vere great is to be found in a reading 01 material contained in the 
Compliance and General Files, for they played an important part in 
oringing into and keeping recalcitrant members in line. (See Exhibit 
N, Section of June 6, 1934. ) 

To cite on particular instance, that ox' Virginia Art Goods 
Company, "here notable work w?s done. This company referred to on 
page 43 of this history applied for exemption on what industry felt 
was an unjust claim. As pointed out Virginia stated they had taken 
no part in the making of the Code and were entitled to exemption under 
6205 3. Industry denied that this was so, and whether so or not, the 
company lived under a wage scale based upon their claim for a differential 
but which was never authorized at least formally oy the Administrator. 
The Code Directors acting upon the good counsel oi Deputy Salter Mangum 
finally visited the factory in Lynchburg and there developed what was 
the basic trouble in making Virginia Art feel their need for a differ- 
ential. Their operative practice was then changed and the company was 
brought into obed.ience. IVe shall have occasion totreat of this more 
fully in a later chapter. 

9811 



-49- 



It will thus be evident that the new body, approaching its 
problems in good spirit, laid out e i airly comprehensive program and 
no one, cm v-ith justice, charge lack oi diligence or conscientiousness 
in tackling their problems. The strides made toward finding the 
answers will be noted as ve progress. 

The two cnief difi iculties facing the Code Authority were 
Representation and Labor relations, other questions were relatively 
of minor importance. Time was perhaps the principal factor necessary 
in ironing o .t the question of fair representation. Of course common 
horse sense had to be brought into play but since all tried to use 
this, we began to see as the months massed a disappearance of the 
suspicions existing at the beginning, and the Code Authority leading 
the way, industry became united almost 100 percent, with one major 
trade association vhich is today continuing and looking for the execu- 
tion of a voluntary agreement. H*-d the governing body not approached 
its problems as it did we would not today see the glimmer of light 
leading toward a Detter state of affairs. 

The second major difficulty, Labor Relations, proved to be our 
greatest stumbling block. On pages 14, 15, -16, 

of this history we have touched upon these briefly and it will be seen 
what the surface reasons were that constantly kept the problem at 
boiling point. However, my own feeling is tnat they were secondary 
and contributory. 

Years of soft living led to the same type of thinking and for 
many years labor relations were purely those of the bargain counter. 
No one stopped to consider that the welfare of laoor did not begin and 
end with bargaining over wages and hours, no one felt that labor was 
an integral part of manufacturing, none cared as to conditions surround- 
ing their factory employees. Naturally when a group is made to feel thay 
are pariahs, demands are perhaps not always made with good sound sense 
and are not based upon existing realities. Such, here as elsewhere 
was the fundamental trouble with labor relations and the situation 
obtaining was to be expected. 

Complicating the matter still further was the internal condition 
of the Pocket Book Makers Union. Strife had existed for a long while, 
finally resulting in a complete over tune of the officials and the 
turning over to, so it was stated, the Communists. 

Further contributing to the situations complexity was a mistake, 
that as Administration Member, I made. The appointed representative 
of labor was a Phillip Lubliner a quite likable man, an official of 
the union, and one who knew his business. He was not overly strong 
physically and was faced with a DOssible serious operation, or so I 
was told, and therefore asked me to urge the appointment of an alternate. 
This I did, and in due time Mr, A, Stein, Manager of the Union appeared 
on the scene. He was the direct onposite in type to Mr. Lubliner, 
much inclined to bluster, given to name calling, not however in meetings 
but afterwards, and generally objectionable in his manner. While 
Mr, Lubliner was not a. well man I came to the conclusion tha.t was used 

9811 



-50- 



as s subterfuge to have a second labor representative present, one 
only voting. It was realized th? t tut alternate should only be 
present when the sitting member was absent but it was not considered 
wise to offer serious objection. This situation did not make for a 
peaceful approach to ouestions involving labor anc I fe< L that all 
drew a si-;h of relief when as a result of the union election unset 
a Mr. Laderman was appointed. He however was not warmly welcomed for 
it was deiinitely felt that he had the Communist taint. 

With both labor and manufacturing groups torn with internal 
strife it may be seen that it -as difficult to improve the relationship 
between the two factors, and in fact at the end not much of accomplish- 
ment in this direction mav be credited to either side. 

Subordinate to these two chief difficulties yet part of them was 
the utter lack of factual knowledge possessed by the industry. The 
industry has been in existence I or about fifty years with never an 
attempt made, prior to 1934, to gather together any frets respecting 
itself and upon ™hich both labor and industry might have formed some 
just conclusions. 

By May 1935 the basis of a statistical and. factual structure was 
in existence and at the end we be-;an to see something of a picture. 
(See pages 6, 7, 8, 9, 10, 11, 12, ofthis history, also Exhibits 
B, - I page l - G- - H - IT page 4 Section dated July 10, 1935.) 

The matter of Homework was a collateral part of the labor problem. 
Prior to 1934 there was but a vague idea of the question and of its 
possible effect upon the industry. May 1935 found completed a first study 
that offered a partial solution of the question. (See Exhibit 4 
parts.) 

Additional to the before mentioned problems was that of cost 
figuring. It is safe to say that prior to the advent of the Code not 
a baker's dozen had ever seriously considered a scientific or ordered 
approach to this matter. In the first six months of 1935 great progress 
was made in this direction and there was presented to the Administration 
for consideration Exhibit F, a plan which although never finally 
approved indicated first steps at least taxen toward the imposition 
upon industry of a usable system that must in the end have helped 
financial positions. 

A constant thorn in the creative manufacturers' side was his 
loss to Style Pir-cv, and for the. first time a real attempt was made 
for possible solution of this problem. (See Exnibit Q,. ^ 

Compliance with anything did not exist before 1934 for no ' ne 
had ever attempted to show a manufacturer the folly of some of his 
competitive practices. Strange, as it majr seem in the light of this, 
compliance presented no great problem for although at swords points 
as they were, every one realized the need of rcme such instrument as a 
code to put a. stop to the foolishnesses practiced. Every one 

9811 



-51- 



therefore welcomed the Code and almost all believed they must make 
an attempt to live up to it, not of course lOCKo, that would have been 
too much to expect from any human aggregation but in the main they 
did so. The well kno-n chisler oi course was always in the picture 
but compared to other industries of this type few came to our attention. 
Hour and .wage complaints that reached the N.H.'A. were small in number 
and trade practice violations almost non existent. (See Exhibit S. ) 
"te tings were inanv in number (set pages 56, 57, 58, .) and invariably 
long drawn out. 

No industry member of the Board had had previous knowledge of 
parliamentary procedure, hence protracted discussions and vociferous 
beyond words, and yet with all a keen desire to govern industry justly 
and wi se iy. 

In an earlier paragraph is listed the committees set up at the 
first official meeting. The composition of these groups was wieely 
made and reports in the appendix (See Exhibits C, G, H, K, 0, F, Q,) 
show the thorough and painstaking care exercised in deliberations. 

Industry of course felt that "dth the coming of the new code era 
miracles would occur and if our own procedure could have been ouickened, 
pernaps seeming miracles would have come to pass. Be that as it all 
may, certain it is, "hen the end came, industry had begun to believe in 
and feel that their Code Authority -ere endeavoring to rebuild a newer 
and better industrial view point, a truer perspective and the aorizon 
had become clearer with orornise of better things to come. 

For those who did not live with the industry during the hectic days 
of 1933 and iy34 it is difficult b understand just what if anything of 
a deiinite nature was accomplished by all the long drawn out noisy 
meetings of this Board and of industry itself. For that matter I, 
myself, find it had to put the finger upon concrete things and say this 
was started, reached this point, and was concluded satisfactorily or 
otherwise. Specific things were done -as referred to above and found 
in the appendix, buti'I feel the most important accomplishment of all 
was a rebuilding of the spirit, a re— examination of values, a weighing 
of position, and a clinching of the determination to fight on and win by 
f-ir means. None of these can be or are put down in. records of 
meetings, they are not always or perhaps oiten expressed but living 
with it one feels it in the air, and -that was the condition at the end as 
against the early cays of fighting and. refusal to consider the other 
fellow and all that that entails. 

The memorandum written by the Administration iember in July 1935 
should, I think, be referred to (see Exhibit N, Section dated. July 10, 
1935) for it gives a. summary, of this Code Authority's activities and 
the picture -s I sa w it. 

3. Organization 

1. 'Vhile Article VI, Section 1 of the Code called for a Code 
Authority of eleven (11) representatives of industry and the order of 

9611 



-52- 



approval specified the appointment ox election of three additional 
members to be chosen from members of industry who are not in the 
opinion of the Administrator adequately represented but ten were 
approved by the order of September bth, 1934 (Order 332-16). The 
eleventh member was. to have been selected by the Ladies Handbag 
Manufacturers of the Facific Coast but apparently no association 
existed, and- as far as the Administration member knew manufacturers 
from this region never communicated with the Code Authority nor 
attempted to elect a representative. The Code provision in part 
follows: 

"Five (5) members shall be selected by the Associated 
Handbag Industries of America, Inc. 

"Two (2) members shall be selected by the National 
Association oi Ladies Handbag 1.1a ruf acturers 

"Two (2) members shall be selected by the Industrial 
Council of Leather Goods ilanuf acturers, Inc. 

"One (1) member shall be selected b-' the i Idlest 
Handbag and Small Leather Viares Association, Inc. 

"One (1) member shall' be selected by the Ladies' Handoag 
uanuf -cturers of the Faciiic Coast." 

In addition to Industry Members provision was made for one 
member to represent labor and such other additional members without 
vote to represent such groups or interests or such governmental 
agencies and for such periods as the Administrator -night designate. 

Industry members were to be selected by and from the four active 
associations (See paragraph 2 of Article VI of the Code above) and 
in fact were elected, first by the several boards of governors and 
ratified by the Associations. 

One labor me iber, Phil"! ip -Lubliner, w? s appointed Aoril 27th, 
1934 (Order 332-2) but on account of ill-health '?s permitted to have 
an alternate. Dissension breaking out in tht. ranks of the Internation- 
al Pocketbook makers Union, Sir. Luoliner arc his alternate, Mr. A. Stein, 
were superseded January 2nd, 1935 (Order 332-20) by Mr. I. Laderman. 

The Administration member, 0«1«. ?ea~ son, serving vi th the exception 
of about two weeks throughout the Administration of the Code, was not 
however officially appointed until May 10th, 1934 (Order 332-3). In 
April 1934, Dr. Paul Abelson was designated, serving at two meetings 
of the Code Authority and one committee meeting. Upon objection 
by out of town .manufacturers his appointment ves not confirmed and 
Mr. Pearson's designation became oflicial. 

The various associations or their Boards of Governors having met, 
made their selections and presented the selected names and credentials 
to the Deputy Administrator and in due time the Code Authority was 

9811 



-53- 



officially approved, under Order 332-16 dated September &, 1934. 

In ilay 1934 evidence of trouble in the Midwest Association's 
ranks came to the Code Authority's attention, various resignations 
took place and a ne" election of officers and delegates to the Code 
Authority was held. In June 1934 rir« M. H. Blumenfeld, i.:irrd Leather 
Goods Company, 4'." 2 South iarket Street, Chicago, Illinois, ws seated 
(See - ,: inutes Code Authority Meetings Nos. 8, 9, 10, 12, held respectively 
May 24, 31, June 6 and 21, 1234). 

As minutes of meetings are studied one notes the presence of 
industry alternates. Such '-ere provided in the 3y-La v 's of the 
Associations and considered necessary because most member's' of the Board 
had factories located in places other then Few York City and in 
addition many "-ere acting as their own salesmen, and thus often on 
the road. The practice m as followed until late in 1934 when the legal 
division pointed out its illegality. (See General Files-Correspondence 
Leigh E, Ore, Assistant Deputy, September 26, October 17, December 12, 
1934). 

June 23, 1934, notice of hearing "-as published for the purpose among 
otners,' of determining whether the Code Authority was ..truly representative, 
hearings "'ere held, lasted one day, adjourned and re-opened July 9th 
and 10th. Immediately prior to the June hearing a. committee of warring 
manufacturers had come to an agreement to consolidate associations, (See 
Exhibit N, Section dated July 2, 1934) and. shortly thereafter it was 
ratified at an industry meeting. 

At the bexore mentioned hearings a new group of 66 small New York 
manufacturers came to light, represented py Archibald Palmer, Z Laiayette 
Street, New York, Attorneyat Lav. They filed, July 6th, 1934 certificate 
of incorporation under the name New York iabricoid and Leather Handbag 
Manufacturers Association Inc. "ith 



iiax S. einman 
Max H. Kasno^-itz 
Julius -;allenzveig 
..'illiam A. Mrschborn 
Edward R, Lowy 
Morris Wunthal 
Herman Rosenz"-eig 
Phillip Lichtenstein 
Herman Feller 



40 . est 20th St. , N.Y.C. 

202 Canal St. , N.Y.C. 

2 ' est 29th St., N.Y.C. 

5100 - 15th Ave., Brooklyn, N.Y. 

38 ; est 32nd St., N.Y.C. 

9 est 31st St. , N.Y.C. 

258 St., Brooklyn, N.Y. 

1605 Nelson Ave., Bronx, N.Y. 

1349 - 57th St., Brooklyn, N.Y. 



as directors. (See General Files and Transcript, Fublic Hearing of June 
7, and July 9 and 10, 1934). This group, also seeking representation, 
"•as composed mainly of small manufacturers, in fact the charge was made 
that they '"ere contractors posing as manufacturers and set up by the 
Union solely for the purpose of creating trouule and sentiment with 
the Administration, that Industry did not altogether see eye to eye with 

9811 



-54- 



the Code Authority. 

HovQver, this may all have been, within a week or two after the 
hearings, nothing more was heard of the group as such. 

The Code Authority set up ouestion was the first subject of the 
June 7 hearing. Industry unoualif iedly said they preferred to have 
the Administration Member make the selection of the additional 
members. (See pages 13 to 22 June 7, and 279 to 333 j u i y g ? 1934 
Transcript of Hearing.) .However nothing '."as done about this at that 
time, it seeming to be impolitic. During that summer and early fall 
a strike was called resulting in many more manufacturers leaving 
New York. Consummation of the consolidation move was not considered 
feasible and not until January 17, 1935 was the appointment of 
additional new members of the Code Authority pressed to a conclusion 
and recommendation made to the Administrator. (See Exhibit N, Section 
dated January 17, 1935.). 

r.iuch consideration va.s given this by the Administration but it 
vss not until some few days before closure that these '"eve approved. 

-iarch 8th, 1954 the Code Authority approaching the close of its 
year in office the Administration member "Tote to the Deputy recommending 
that the body should be continued until the expiration of the N. I.E.A. 
June 16th, 1934. (See Exhibit N. page 3 of Section dated iarch 8, 1934.) 

In December 1934 and January 1935 a series of conferences were ■ - 
held between the Imitation Leather Novelties Group of the Luggage 
Code end the Ladies Handbag Code Authority Directors looking toward 
the absorption of the first named by Handbags. A deputation was 
received at the Handbag Code Authority meeting held January 3rd, 1935. 
(See Minutes Meeting v25, General Files, and. Administration Members 
report January 4th, 1935, Exhibit F. ) 

Consolidation was in essence agreed to anc had it been confirmed 
would nave brought to tne Handbag Code Authority an additional two 
members to represent that group. 

With the exception of the changes- noted in this chapter the 
Code. Authority regained as originally constituted until the Supreme 
Court's decision.. 

2 . Fersonnel o f_t ne Code Authority 

The. following were the members certified by the Associations 
as having been elected: 

By the Associated Handbag Industries of America Inc . 

Harry Schoenfeld - President Schoenfeld & Wolf Inc. 

14 East 33rd St., N.Y.C. 
Morris Immerman - President Bagcraft Mfg. Inc. 

30 East 33rd St., N.Y.C. 

9811 



-55- 
Eichard Koret - President Koret Inc. 

33 East 33rd St. , N. Y. C. 
Maurice Magid - Partner A. I. Uagid & Co. 

14 East 33rd St. , N. Y. C. 
*Sol l.ir.tterperl ■ - President Sol Mutterperl Inc. 

330 Fifth Ave. , N. Y. C. 

By the Industrial Council of Ler.th.er goods Manufacturers, Inc. 

Irving Schoenholz - President Schoenholz & Weeks Inc. 

15 Last 32nd St. , ST. Y. C. 
•William Kadin - Vice Pres. & T r eas. Kadin Bros. Inc. 

132 West 36th St. , N. Y. C. 

By the I^tiona! As sociation of Ladies Handbag Manufacturers 

*Samuel R, Goldsmith - President Goldsmith Bros, Mfg. Co. ,Inc. 

38 West 32nd St. , Iff. Y. C. 
*G e orge L. Meyers - Partner Meyers Mfg. Co. 

330 Fifth Ave. , N. Y. C. 

By the Midwest Handbag d- Small Leather Wares Association 

*3. Malow (Position not stated) Crystal Leather Goods Co. 

34 So. Wells St. , Chicago 111. 

Administration Members 

D r . P a ta Abelson, 11 West 42nd St. , N. Y. C. 
0. W. Pearson 45 Broadway, II. Y. C^ 

Dr. Abelson, r lawyer, has been for many years impartial chairman 
of several industries notably Furs and Millinery. No connection with 
Hand Bags, 

0. W. Pearson an advertising man connected with Dry Goods Pub- 
lications and quite familiar with the distributive problems of consumer 
goods going through -wholesale and retail dry goods and department stores. 
Accredited to ten different industries as Administration Member but had 
no connection financial or otherwise with any. First appointed as rep- 
resentative of Dr. Howard the latter part of March he was not made offic- 
ial until May as .stated in the foregoing paragraphs. 

Representing L a bor Advisory Board 

Phillip Lubliner 

Code Directors and Executive Secretary 

A. Mittenthal 

M#" Berkowitz 

Maurice Mosesson, Executive Secretary 

(See Exhibit I for breakdown into types of merchandise and size of Code 
Authority.) 



9811 



-56- 

The composition of the 'Board fallowed the rule laid down in 
Article VI, but it is interesting to examine Exhibit T. , compare with 
the commonly accepted groupings of price ranges and see that each 
was fairly represented.' " 

The addresses given are those of the selling offices which are 
located in New York City. Those marked with an asterisk are out of 
town manufacturers and regardless of Association affiliations it will 
be s 3on that the out-hf-t^wners obtained frcm the Deputy in charge a 
fair consideration. 

Thirty-one meetings of the Code Authority and thirty- seven meetings 
of Committees Here held, Administration being represented at all Bode 
Authority gatherings v/ith frequent attendance at committee meetings. • 
Three industry mass meetings also took place. 

Pile show copies of minutes of but twenty-one meetings and there 
are missing many repo'rtg from the Administration member. The administrat- 
ion Member's reports are contained in Exhibit K. 

RECORD OF CODE AUTHORITY I-ffiSTIHGS 



IT 1 110 NUMBER- 


DATE OF 2JEETIITG 
March 23, 1934 




PLACE 


1 


New 


York City 


2 


March 29, 1934 




it 


3 


April 3, 1934 




ti 


4 


April 11, 1934 




n 


5 


April 26, 1934 




it 


6 


May 3, 1954 




it 


7 


May 10, 1934 




it 


8 


May 24, 1934 * 




ii 


9 


May 31, 1934 




ii 


10 


June 6, 1934 


Washington, D. C 


11 


June 14, 1934 


New 


York City 


12 


June 21, 1934 




n 


13 


June 23, 1934 




n 


14 


June 28, 1934 




ii 


15 


July 5, 1934 




ii 


16 


July 9,1034 


Washington, D. C_ 


17 


July 20, 1934 


New 


York City 


18 


August 2, 1934 




ii 


19 


August 23, 19& 




ii 


20 


Sept. 4, 1934 




it 


21 


Sept 27, 1934 




it 


22 


Oct. 25, 1934 




n 


23 


Nov. 8, 1934 


New 


York City 


24 


Dec. 6, 1934 




H 


25 


Jan. 3, 1935 




11 


26 


Feb. 19, 1935 




II 


27 


March 11, 1935 




II 


28 


April 4, 1935 




II 


29 


May 21, 1935 


Washington, D. C. 


30 


June 3, 1935 


New 


York City 


31 


June 11, 1935 




ii 



9811 



-57- 



RECQRD OF CO;.JuITTEE MEETI ITGS 



COMMITTEE 



BATE OF I.SETIITG 

March 28, 1934 
April 16, 1934 
April 18, 1934 
April 28, 1934 
April 30, 1934 

May 7, 1934 

June 22, 1934 
June 2G, 1934 

July 18; 1934 
July 31, 1934 
July 30, 1934 



Finance Committee 
Finance Committee 
Beaded Bag Group 
Finance Committee 
Finance Committee 

Beaded Bag Group 

Steering Committee 
Steering Committee 

Beaded Bag Group 
Emergency Committee 
Committee to study exist- 
ing conditions in the 
industries 



August 1, 1934 

August 24, 1934 

August 28, 1934 

August 30, .1934 

September 4, 1934 
September 6, 1934 
September 13, 1934 
September 17, 1934 
September 21, 1934 
September 25, 1934 

October 2, 1934 
October 9, 1934 

October 15, 1934 
October 31, 1934 

November 7, 1934 
November 13, 1934 
November 16, 1934 
November 20, 1934 
November 21, 1934 

December 3, 1934 
December 15, 1934 
December 18, 1934 
December 27, 1934 

M a rch 2, 1935 
March 7, 1935 
M a rch 11, 1935 



Small Committee 
Beaded Bag Group 
Beaded Bag Gioup 
Label Committee 

Labor Committee 
•Label Committee 
Labor Committee 
Label Committee 
Labor Committee 
Labor Committee 

L a bor Committee 

Trade Practice Complaints 

Committee 

Uniform Cost Formula Committee 

Special Committee 

Scpecial Committee 
Label Committee 
Style Piracy Committee 
Style Piracy Committee 
Label Committee 

Home wo rk C ommi 1 1 e e 
Beaded Bag Group 
Cost Accounting Committee 
Design Piracy Committee 

Budget & Label Committee 
Budget £: Label Committee 
Budget & Label Committee 



The above meetings took place in New York City 
9811 



-58- 

3. Changes in Code Authority 

The following summarizes the changes made from original personnel 
as set forth in the foregoing paragraphs: 

1* Dissension in ranks of Midwest Association of Chicago led to the 
election of 

Mr. H. Blumenfeld 

Mirro Leather Goods Company 
402 South M a rket Street 
Chicago, Illinois 
in place of the original member from that area, 

Kir. S. Marlow. 
Certified to the Code Authority and the new member, Mr. Blumenfeld, 
recognized with the other members September 1934 (Order 333-16). 

(2) A complete overturn in the International Pocket Book Workers Union 
brought about the unseating of all officers and 

Mr. I. Laderraan 

succeeded Mr. Phillip Lub liner (Order 332-20) as Labor represent- 
ative. 

(3) Dr. Paul Abel son was appointed to succeed 0. W. Pearson as Admin- 
istration Member but the appointment was not confirmed and as prev- 
iously stated with the exception of two meetings Dr. Abels:n never 
functioned. (SEE Exhibit U). 

(4) Agencies of the Code Authority 

There were none, all work confidential or otherwise being con- 
ducted by the staff of the Code Authority. 

( 5) Field Organization 

There was maintained a staff of six field investigators reporting 
to the co-code director Mr. Max Berkowitz who was responsible 
for all compliance activities. 

These men ?;ere retired manufacturers, practical men of age, ex- 
perience and standing and respected by all. 

Additional to following the usual policing procedure of most code 
authorities, examination and study was made to find the answer to 
the oft voiced plea that it was difficult if not impossible to 
meet code requirements and industrially live, in many cases the 
answer being found in bad sloppy factory practice. 

Frequent visits were made to almost all factories except those 
on the Coast, in Texas and Florida. 

The code Directors tock great pains in the selection of their 
staff and I can safely say they were of much higher grade than 
those employed by many other industries. 

9811 



-59- 

While no attempt was ma.de to condone failure to live up to the Code, 
searching constructive examination v/as made to disclose the weak spots of 
factory practice and to strengthen them. 

These men did not consider themselves as policement but rather 
as counsellors and friends and their work took them far afield of the 
usual activity of such men. 

'Their first concern was naturally the scanning of payroll and 
time records but they also took' time to study merchandise on the 
counters of re'tail stores, checking of labels used, and as practical 
men determining or at least gaining an idea, from the price and values 
offered if manufacturers were misbranding or underpaying their employees. 

Some manufacturers were not always honest in their record keeping, 
and an analysis of their product sometimes disclosed that at the price 
offered, they were so c.oing, and rechecking proved the point. 

Pains were taken by the Code Directors in checking false adver- 
tising of Retailers and much was accomplished in this direction. 

In earlier chapters of this history mention has been made of 
the dissension existing and the causes thereof. This staff by its 
uniform painstaking care and fairness, its willingness to counsel, 
unquestionably played a part in the peace pact that v/as made and 
Industry began to get, at least a glimmering of appreciation and 
understanding of what a code was designed to and could do. 

Naturally there were some who could not see the light. The out- 
standing instance of this in the first months was the manufacturer 
referred to in the Administration Member's reports. (See Exhibit N. 
Section dated April 5, 1935) and in the following letters from the labor 
union. 

"NEW YOEK JOINT COUNCIL 

INTERNATIONAL POCICTBOOK WORKERS UNION 
Affiliated With 

American Federation of Labor. 

U a j 22nd, 1934 
Mr. Oliver W. Pearson, 

Code Authority, Ladies' Handbag Industry 
N. R. A., 
45 Broadway, 
New York City. 

Dear Mr. Pearson: 

The Stylecraft Leather Goods Co. located in Bridgeport, Conn., a 
subsidiary shop of the Morris White Manufacturing Co. of New York 
has openly challenged the authority of the code authority of the 
industry and has hired close to twenty-five apprentices in violat- 
ion of our Handbag Code. 

9811 



-60- 

The Union has already registered several complaints for violations of the 
Code with the Code Authority as well as with the 11. R, A* Offices in the 
State of Connecticut against the Stylecraft Leather Goods Co. but the firm 
instead of paying any attention to our complaints, is openly defying the 
Code Authority. 

I s n't it strange that the Morris White Mfg., Co. and the Stylecraft Leather 
Goods Co. , which firms had received at the beginning of the year a loan in 
the amount of iplOO.000 from the R. E. C. to conduct their business, 
should challenge the Code Authority and defy the N. R. A.? The situation 
is more menacing becaiise of the fact that Morris White is openly boasting 
before other manufacturers of said daring exploits of taking on numerous 
apprentices in defiance of the Code Authority which makes for general de- 
moralization of the entire trade. 

Your immediate attention and action is most urgent. 

Waiting to hear from you, I am 

Very truly yours, 
(Signed) A. STEIN 

BSccAU Manager" 

12646 

AFoL 

The situation here referred to resulted later in the matter being 
brought before the Compliance Board and restitution made. Of this we 
shall deal later. 

A few others, generally small in size also proved troublesome but 
in the main industry reacted spendidly. 

Complaint was made that the Code Authority and its Directors were at 
times stiff necked, that they were Eastern Manufacturers and without 
national view oint or ability to get one. Tv-o outstanding instances of 
this were the he eke r Company of Joplin, Hi ouri, and the Virginia Art 
Studios of Richmond, Virginia. The files are replete with their volum- 
inous communications. 

Exhibits V and W indicate the care exercised to answer and explain 
positions takeii in a refusal of the Meeker Company's plea, and the 
Virginia Art file shows a complete reversal of the position consistently 
taken by them in their pleas for differentials through the first year or 
fourteen months of Code life. 

Other manufacturers from time to time complained, for a moment 
or two at any rate, of the consistent position of refusal taken by the 
Code Authority with respect to individual requests and pleas, but almost 
invariably decisions made were gracefully a.ccepted. These pleas were pretty 
much of the same tenor, applications for over time, two shifts, appren- 
tices and wage differentials. 

Reference was made above to false advertising by Retailers. An in~ 

9811 



-61- 

stsnce of thin was a long drawn out controversy with one of the large 
New York Department stores. Checking of metropolitan advertising indicated 
that at the price offered goods could not be of the material described and 
finally led to withdrawal. The administrrtion member was quite familiar 
with this and corroborative.evider.ee of this and other similar trans 
actions may be found in the late Code Authority files now in the hands of 
the succeeding organization. 

Statistical reports in Exhibit E and included in pages 6, 7, 8, 
9, 1C, 11, 12 of this history are by no manner of means complete but they 
give a picture of the character of work done. 

6. Discussion of Operation of Code Authority as an 
Industr;, Governing Body . 

In considering this subject one must constantly keep in mind two 
factors that for several months after the induction into office of this 
Code Authority were ever in the foreground of industry 1 s consciousness. 

First: A considerable proportion of production was in the hands 
of factories located outside the city limits of New York, who were paying 
wages much below New York unionized factories. 

Second; The Code Authority's own sharp division in membership, as 
between Hew York, and out of town, with the outlander element feeling 
chagrined and worse over the division of representation made by the 
Administration.: 

Obviously this situation made matters difficult, for each group 
found it almost impossible to rise to their opportunity of self 
government and weight dispassionately the problems given birth to in, 
and by the Code. 

The feeling existing from these factors could not be treated light- 
ly and had if pos ible to be smoothed out. The problem cut several 
ways. Out of town factories paying an average of considerably less than 
ten dollars per week found themselves raised to a code reqtiirement of 
fourteen dollars minimum, a raise upsetting their equilibrium and 
assuming a size in their mental reckoning out of all proportion. 

The ITe« York faction felt, naturally so perhaps, that the out of 
towners would find ways to beet the Code, not yet realizing the searching- 
quality of the police machine that was about to come into being. Ex- 
pressed openly or not, the out of town men sensed this suspicion and 
did not take kindly to it. After all their honesty of purpose was being- 
impugned before they had a chance to prove or disprove their good intent, 
in other words were condemned before being tried. 

The representative question then became of greater importance than 
ever, for out of town without a majority, were certain in their minds, that 
they could not hope for a fair break and did not hesitate so to say. 

Ergo: - Confusion - suspicion - distrust openly arrived at - Openly 
expressed. 



9811 



-62- 

The first thing to do was to find a common ground and work from that 
Administr tion in Washington had unsuccessfully tried it, industry had 
tried it in How York neither without apparently getting anywhere, but the 
Administr-.tion member realized that underneath all the strife, there was 
•a feeling, thrt given a fair chance, the Code was a heaven sent gift and 
could help all a long way upon the road of renewed success, such as they 
had once known. It ':as upon this premise- thrt renewed and continuous 
effort v:as ur.de by all concerned and resulted in the"get together" of the 
summer and fall of 1934. 

New York a unionized city had classification, they wanted such in- 
cluded in the Code, thev were unsuccessful, the open shops did not want 
such, could not see it, as applied to their own practice. All felt that 
Section 2 of Article IV which treated of semi-skilled taken in conjunc- 
tion with paragraph one of the order was the hand writing on the wall 
that classification was the death's herd at the feast, the ogre to be 
feared, 

notwithstanding these fears, the Administrator and his Deputy to 
the contrary notwithstanding, the openly made statement of labor that in- 
dustry was dodging the issue and delioerately so, the loiowledge that 
Colonel Lea had opposed its inclusion because of his realization of the 
impossibility of writing a definition, the Code Authority did make an 
earnest, sincere effort to set up and define the term. It is unfortu- 
nate thrt mere written reports cannot give a true picture of the labor 
and turmoil that went into this, the time consumed. Code Authority mem- 
bers felt they were charged with a duty which they tried to carry oiit. Un- 
successful, of course they were, nevertheless they tried. 

Good came from it all, for more than any other factor it brought to 
pass a greater respect for each other and a willingness to see the other 
f ellow' s viewpoint. 

Discussion if this and other labor problems resulted in the public 
hearings of June and July 1934 and the protracted negotiations respect- 
ing hours, classification and wages that never were settled at the time of 
the Supreme Court's decision on N. E. A. 

It also had hearing upon the strike called in the summer of 1934 
which gave great impetus to the migration from New York started some 
years earlier. 

This migration brought in its train charge : by the labor union again- 
st two manufacturers under Section 7 ( a) of N. I. E. A., in that the 
owners had refused collective bargaining. These complaints caused fur- 
ther distress and consumed a great amount of time upon the part of the 
Code Authority and other interested parties. It was felt that the 
charges were not justified for the collective agreement had expired and 
the Union to enforce its demands had called a strike. 

In one of these two cases it developed that the partners of the 
concern, because of their financial situation which prevented the obtain- 
ing of sufficient banking accomodation in Hew York, had been negotiating 
elsewhere for some two years for factory sites and financial help. The 

9811 



-63- 

strike having he en called, negotiations with the union stopped being off- 
ered, hank accomodation provided they take some 200 workers off relief 
rolls, and good factory accomodation manned by experienced workers, it 
was natural to move, in fact there seemed nothing left for them to do, 
if they were to continue their business. This case was finally disposed 
of by the national Labor Relations Board as being "no case" at least 
tht t is the recollection of the Administration Member. The other case ; 
somewhat' different and flagrant was decided against the manufacturer. 

Home work in the Beaded Bag section of the industry was always in 
one's consciousness and much was done by the Authority and its Directorate 
in an attempt to ameliorate home workers' rates of pay. Exhibit gives 
indication of the thought and time devoted to the problem. The matter was 
not settled but had the Code continued it was hoped that the plan laid 
down would have been tried out and possibly have been successful at least 
to the extent that half a loaf is better than none. 

Compliance work was as has been stated in earlier paragraphs of a 
character that was constructive, and positive rather than negative in its 
nature and General Files, Compliance Piles, Code Authority Files give a 
clear picture of this. Statistics give only an Indication of work done 
(Exhibits ?. and S) , one had to live with the responsible officers to 
appreciate the sympathy, understanding, tactfulness without condonation 
of misbehavior, with which this work was done. 

Trade Practices in general, discounts and datings, misbranding ''oy 
manufacturers and retailers, style piracy, cost figuring, retailers ad- 
vertising and offerings, general welfare, relationships with related 
industries, received much of the Authority's thought, time and attention, 
and results were showing in the last few months of its life. (See Exhibits 
C, E, G, H, K, Q,, P, 0, S. X and pages .48,. 49, 50, 51, 52, 58, .53 and 60 
of this history). 

At no time in the memory of the writer was there discrimination shown 
against large or small, out of town or in town, south and north, east 
or west, nor, although labor will not altogether agree, against labor it- 
self, and this last in view of the tense situation of some years standing 
was rather remarkable. 

To sum up briefly; perhaps the best evidence of the success of the 
Code Authority, its paid personnel and particularly its two Directors is to 
be found in the fact that just prior to the Supreme Court's fatelul de- 
cision a dinner was tendered to the Directors by the entire industry. From 
far and near several hundred manufacturers came to pay tribute and to 
publicly state their belief in and knowledge of the success of the work 
done and to express their feeling that all had been fair and just in their 
dealings, 

C. B udget and B£sis of Assessment 

1. Section 6 Article VI of the Code provides that: "Members of 
Industry shall be entitled to participate in and share the benefits of the 
activities of the Code Authority and to participate in the selection of 
the ...embers thereof by assenting to and complying with the requirements 
of the Code and sustaining their reasonable share of the expenses of its 

9811 



-64- 

administ ration. Such reasonable share of the expenses of administrrtion 
shall be determined by the Code Authority subject ^o review by the Admin- 
istrator on the basis of volume of business and/or such other factors 
as may be deemed equitable." 

Article VII - N. R, A. Labels - Section.l reads "All merchandise 
manufactured subject ot the provisions of this code shall bear an N. R. A. 
label, or authorized substitute therefore, to symbolize to purchasers of 
said merchandise the conditions under which it has been manufactured." 

Section 4 of the same article sta.tes in part that: "Any and all 
members of the industry may apply to the Code Authority for a permit to 
purchase and use such N. R # A labels, which permit shall be granted to 
them, but only if, and so long as, they comply with this Code." 

Section 6 of the same article provides: "The Charge made for labels 
by the Code Authority shall at all times be svibject to supervision and 
orders of the Administrator and shall be not more than an amount nec- 
essary to cover the actual reasonable cost thereof, including actual print- 
ing distribution administrrtion and supervision of the use thereof as 
herein above set forth". 

Thus leaving financing of C de Authority activities somewhat indef- 
inite, hence there was approved July 3, 1954 Amendment No. 1 to the approv- 
ed Code providing for mandatory collection of assessments for financing 
purposes. Order No. 333-13 approved by Sol A. Rosenblatt, Division 
Administrator, Hugh S. Johnson, Administrator. 

First financing was by small loans from individual members of the 
C.jde Authority. Money so raised served to pay the small costs of temporary 
quarters but did not suffice for salaries so that employees worked foe- 
some considerable time before being paid. Later a temporary bank loan was 
arranged which served until revenue from assessments and labels came in. 
Frirn that point the Authority was always solvent and operating under reason^ 
able costs. 

Three budgets were submitted. The first was approved but stayed, the 
second a revision of the first, covering one yen- from March 26, 1934 to 
March 3b, 1955. The' third for one year from March 26, 1955 to March 25, 
1936. Of the last submitted, but a portion covering the period from 
March 26, 1935 to June 16, 1935 was approved, and subject to an extension 
of the Code by operation of the law, conditionally approved from June 17, "' 
1935 t« M a rch 25, 1936. 



Period of 
Btxdgets 



1. 3/26/34 

to 
3/26/35 

2. 3/26/54 

to 
3/26/55 * 



Amount 



$140,180.00 



133,540.30 



Date Approved 
May 23,1934 
Stayed - 

June 9, 1934 



Order Ho. 
332-8 

332-11 



July 16, 1934 332-14 

( Resubmit ted) 



9811 



Period 

of .Budgets Amount Date Approved Ord er Ho. 

3/ 3/25/ 55 $110,641.00 May 24, 1935 332-25 

to 






3/25/36 



Basis of Contribution 



Budget Ho. 1. 1/3 of ifo of the dollar sales volume 
Budget Ho. 2. 1/3 of Yp of the net dollar sales volume 
Budget No. 3. l/4 -of 1$ of the gross sales volume 

ESTIMATED INCOME 

Budget No. 1 • '•■ ■ • $149,999.00 

Budget No. 2 149, 999.00 

Bucget Ho. 5 110,641.00 

(1st period) $31,540.00 

(2nd period) 79,101.00 

(See pages 1, 2, 3 - Exhibit Y. ) 

At the end of the first budgetary, period, finding a substantial 
surplus in excess of -$40,000 in its treasury, the Code Authority con- 
cluded to refund $30,000 to industry and passed on March 7, 1935 a formal 
resolution so ordering, and by M a y 3, 1935 approximately $23,000 had 
been paid* (See page 5, Exhibit Y. ) 

It will be seen from the foregoing that the Code Authority and its 
paid officials v/ere cautious and watchful in financial operations and 
my own feeling as Administration member was that in some directions they 
were overly so, for they needed the services of a least two extra men to 
cover the South and far West, and of statisticians to enable a proper 
and full statistical study of industry to be made. 

2. Termination of Paragraph 3 of Administrative Order X-36 

July 27, 1934 Acting Division Administrator William P. F a rnsworth 
signed Order 332-15 terminating the exemption conferred in Paragraph 
III of Administrative Order X-36 dated May 26, 1934. Opportunity 
to be heard had been given in notice Ho. 236/l/01 dated June 15, 1934 
and no objections were filed. There was at the time considerable over- 
lapping in the bag industry particularly with the Luggage and Fancy 
Leather Goods Industry and to some extent with the Woman's Belt Industry 
and if the exemption granted under X-36 were allowed to stand the Hand 
Bag Industry bade fair not to meet budgetary requirements 

3. Effec t of other Administrat i ve Orders. 

Is it necessary to point out that the constant delay in" the issu- 
ance of Administrative Orders approving budgets were to say the least 
disturbing and gave rise ti much bitter criticism? Industry recognized 
the right and need of checking, but certain questions raised, were deemed 

9811 



-66- 

none of tlie Administration's business, were resented and this militated 
agai n s t smo o th f unc t i o ni ng. 

It was constantly pointed out th? t what was being done was for the 
protection of the Code Authority itself, but none the less the answer 
ever made was "we know our industry, either we are trusted or we are not 
and we still think Administration is over reaching itself and in any 
event there can be no excuse for the delays." It is to be remembered 
thrt in the latter days there was 'less" delay than formerly but there 
still remained the v/onder, How Long ch Lord, How LongJ 

4 « , fc£fr-f*e from l/>g,ls. 

It was originally proposed that labels should be sold at a profit 
sufficient to finance the operations n f the Code Authority. Preliminary 
conferences were held by the Deputy and his advisors with the Directors 
respecting this and upon objection it was determined that a levy of l/3 
of Vp upon sales would be preferable and that labels shouldlbe sold at 
cost plus. It was consequently so ordered in Administrative Order 332-8 
and the later Order 332-14, 332-25. Proper regulations were set up, under 
which industry ordered and were supplied for cash, sufficient for not 
more than three week' s operation. 

Mr* A. A. Fisher in his report to the Deputy made part of this his- 
tory, page 3, Exhibit Y states in detail that the total sales of labels 
were 37,4-32,000 and that these were purchasec after bids from several sources 
of supply at a price of $14,884.00. (lIOTE: Reference is made to sticker 
labels; these were only to be affixed to merchandise already in stock on 
July 2, 1934) Industry was required to file with the authority a monthly 
statement and without such, labels could not be issued. The use of labels 
was salutary serving as a compliance weapon, and to further the laying of 
foundations of a statistical structure. 

Page 4 Exhibit Y gives in detail the income received during the 
pericd covered from March 36, 1934 to February 28, 1935. This totaled 
$105,799.29 with a total expense of $65,574.44 leaving a surplus of in- 
come $40,224.85. This as stated in a previous paragraph and on page 5 
Exhibit Y was in part distributed pro rata to industry, creating an ex- 
cellent impression, 

5. Pr opo rtion o f Assessme nts Collected 

The collection of assessments was a simple matter, for the label 
regulations provided for a filing of sales reports with the Arithority 
and unless the approved percentage was paid labels did not issue. 

At the beginning there was some confusion, or perhaps a slight 
holding back, until it was found that distributors would not accept 
merchandise without labels. From then on, there was no trouble, col- 
lections being made from IOj^j of industry, with a small amount, $600, 
that proved uncollectible, and this held all the way to the end. 

6. Financial Operations of Cod e Aut hority in Relation to its Other 
Operation s 

9811 



-67- 

In an earlier paragraph of this chapter it was remarked that the 
Directors were overly cautions in their financial operations. This per- 
Laps should be qualified by adding, that they needed to be bec.-use of the 
make up of the Cede Authority. At the beginning of this history it was 
pointed out that never at any time had the industry thought it necessary 
to really know itself, to obtain a knowledge based upon facts. Not having 
been accustomed to the idea, one had to approach the matter circumspectly, 
with a feeling that cue had perforce to crawl before attempting to walk. 
It must not be thought that over Caution to the point of hamstringing was 
the order of the cay, but neither must it be forgotten that a start from 
scratch, necessarily entails much greater energy than keeping a going 
machine moving. On the whole the financial set vx> was good and did permit 
competent and fairly adequate operation. 

D. Administration *f the. Code 

1» Amendments 

There were a number of Hand Bag Manufacturers making products 
other than H a nd Bags, principally luggage and fancy leather goods. These 
claimed that jurisdiction belonged to the Luggage and Fancy Leather Goods 
Code since from their point of view it was a more advantageous code under 
which to operate. With the somewhat indefinite financing provisions of 
the Ladies II a nd 3 a g Code it was necessary to clarify the situation. After 
discussion wi±h the Assistant Deputy it was determined wise to move for an 
amendment to the Hand Bag Code and such amendment No. 1 was written, passed 
by the Code Authority, submitted to the Administrator, opportunity to be 
heard given Order 333-12, and finally a_> proved by Order 333-13. 

In preparing the order for approval the Assistant Deputy noted 
that the Hand Bag Code Authority would be unable, due' to overlapping, pro- 
vide 'sufficient revenue to meet its budgetary requirements. From that 
point on there was no trouble in financing. • 

The constantly recurring question of the semiskilled defi- 
nition coming up for public hearing in June, a special meeting of the Code 
Authority was held on the day of the adjourned meeting in "Washington, July 
9, 1934. There was introduced a resolution, later carried, that there 
be deleted from the Code Section 2 of Article IV, and further that Section 
6 of Article IV like wise be removed. (See minutes of meeting No. 16 July 
9, 1934 General Files) Labor made strenuous objection to these resolu- 
tions anc continued so to do in the ensuing months. An order covering this 
was drawn up later in the year, 1934, but never consummated due to the 
interlocking question of wages and hours not having been settled, and the 
matter dragged along until the winter of 1934 and 1935. February 7, 1935 
notice of hearing was issued (No. 367-F) and this subject was included 
with other proposed amendments submitted by the Code Authority (See Trans- 
cript Public Hearing Febiuary 28 1935 pages 86 to 224). 

A serious problem affecting all consumer goods industries 
particularly where such are distributed tnrough department .stores- is 
that »f what is known as "Return Goods". Apparently orders placed by re- 
tail merchants have not altogether been considered "firm" orders, the re- 
tailer, if so be he had changed his mind or found his judgment as to 

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salability not so good, reserving the right to return goods at will. At 
one time, this seems not to have been the case, none returning goods, unles: 
for the substantial cause that they were not up to sample. Of late years 
however merchants have not hesitated to return goods for almost any cause 
notwithstanding they were made up by the manufacturer in good faith 
and shipped according to instructions. Merchants, if they found busi- 
ness in a slump, a periodic occurence, had no compunction over passing 
the buck to the manufacturer, in other words expecting the manufacturer to 
pay for hie, the retailers sins of omission or commission. In the good 
years with producers, retailers could seldom get away with the practice 
and never with the well organized and financed manufacturer, but in times, 
suchas we have been having the practice of returning goods by even the so 
Galled reputable outlets has reached monstrous proportions. 

The Hand Bag Code Authority trchled the problem in earnest, and were 
desirovis of amending their Code so that it would be prohibited, but found 
it an impossible task to find a satisfactory answer so that no actual 
amendment covering this was ever presented. (See page 2 minutes, meeting 
NO. 12. General Files). 

August 2, 1934 the Code Authority at meeting No. 18 passed the 
following resolution] 

"Hesolved that Section 1 of Article II be 
amended by inserting the words ' shopping 
bags, bathing bags, handkerchief bags, 
vanity boxes, cosmetic bags, utility bags, 
knitting bags' in the first sentence after 
the word 'purses' so that Section 1 of 
Article II will read as follows; 

"The term 'industry' as used herein included 
the manufacture of Ladies' , Misses, and 
childrens handbags, pocket books and purses, 
shopping bags, bathing "orgs, handkerchief 
bags, vanity boxes, cosmetic bags, utility 
bags, knitting bags, manufactured of any 
material of an3' kind or nature,. The term 
'industry' shall not include however, the 
manufacture of handbags, pockc-tbooks, purses 
and mesh bags manufactured in whole of metal. " 

This was submitted to the Administration and after much discussion 
with the interested parties was noticed for hearing (367 - E December 
19, 1934) and heardJ a nuary 9, 1935. 

At this hearing, it is to be noted in the Transcript, that as an 
agreement was about to be reached between the opposing parties as to 
which of the many articles brought in as evidence should be included in 
the proposed new definition, it was found necessary to seek Colonel 
Brady's opinion. (See page 48, Transcript, Public Hearing, January 9, 
1935). To every ones seeming surprise, Colonel Brady rendered a sweep- 
ing decision that all bags on exhibition were Hand Bags. This broad 
statement was disconcerting, created much discussion, brought about many 

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conferences and it was not until almost the close of the Code that a 
satisfactory definition was prepared and submitted for approval. This read: 

"The term 'industry' as used herein includes the 
manufacture of ladies, misses, and children's hand- 
bags, pocket-books and purses, shopping bags, 
bathing bags, handkerchief bags, kiddy bags, 
vanity boxes, cosmetic bags, knitting bags, manu- 
factured of any material of any kind or nature. 
"The term 'industry', however, shall not include 
articles commonly manufactured by the Luggage and 
E&ncy Leather Goods Industry used -for traveling 
purposes, nor over- night bags for 'what ever pur- 
pose used, nor any article manufactured for men's 
only, nor the manufacture of hand bags, pocket- 
books, purses, vanity cases and mesh bags manu- 
factured in whole of metal.-'-" 

The Schechter case decision having been made the matter naturally 
dropped. 

The minutes of meeting Wo. 18 also note that the Code Authority ex- 
pressed itself in favor of amending the Cnde with respect to Price Groupings 
The following excerpt from minutes of that meeting, page 2 and 3, and 
Exhibit E indicate the reasoning applied as does a later brief written 
by the code Director Mitt en thai. (S e e Exhibit Z) . 

At this same meting No. 18, the following resolution was presented 
and passed: 

"EESOLVED that the Code of Pair Competition for the 
Ladies' Handbag Industry be amended by 
inserting a tra.de practice rule which 
shall be known as Section 16 of Article VIII 
to read a.s follows: 

"'No member of the industry shall repair bags 
without making a reasonable charge for such 
repairs, when such bags show that they have 
been in use. No member of the industry shall 
pay any forwarding charges for such repairs." 

This proposal led to considerable discussion and epposition but 
was finally presented in the folowing form 

"No member of the Industry shall pay for or rebate forwarding charges 
incidental to the return of used handbags, or repair used handbags without 
making a charge for same based upon the cost of labor and materials required 
for making such repair. This provision shall not apply, however to repairs 
attributable to defective workmanship or materials. Actual forwarding or 
transportation charges shall be separately itemized on invoice." 

noticed for public hearing (367 - E December 19, 1934 heard January 9, 1935 
approved May 23, 1935 and to be known as Section 16 of Article VIII - Order 
332-24). 

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The reasons "back of this move are interesting. In the relationship 
"between producer and seller, there has been a feeling that much "buck 
passing was talcing place. 

Times "being good, profits with the producer excellent, not much 
attention is paid to such matters. Retailers finding merchandise move- 
ment slowing up, take advantage of every thing possible, no matter what, 
to quicken sales and more particularly when it can be done at some one 
elses expense. Undoubtedly in good times retailers would not return mer- 
chandise to a manufacturer for repair unless it were palpably faulty, but 
of late years faults obviously developed as a result of wear or careless- 
ness were charged to manufacturers. The retailer however, it is claimed, 
charged his customer for "repair- but on the other hand asked the original 
producer to make such at no cost to the retailer. If these statements 
are correct, and we are assured they are, one must admit it to be a repre- 
hensible practice and anything of a legitimate nature looking toward clean- 
ing the stable of bad practice is to be desired. 
(Refer to pages 98 to 103 Transcript Public Hearing January 9, 1935.) 

Design Piracy is an evil we have always had with us. The "brains 
of the creative world as well as those of the legal (patent) fraternity, 
have been turned over and over looking for a check upon the light minded 
gentry, who hesitating to illegally take ones money or property, have 
not thought it amiss to steal idea.s from" their more creative brethren. 

All governments have over the years tackled the subject, and as far 
as one can quickly determine, have not been altogether able to find a 
satisfactory answer. Certainly the public hearing held January 9, 1935 
developed the difficulty of obtaining a meeting of minds. (See pages 
68 to 98 Transcript of Hearing) and it 'is well to look at Exhibit Q, 
which gives an outline idea of the time and thought put into this by 
the Code Authority and its officials. 

The Administration had not made their decision as to the advisa- 
bility of including this as an amendment when the act was declared void 
and so the matter rested. 

The minutes of Code Authority Meetings indicate that at meeting 
No. 21 held September 27, 1934 a proposal to amend the Code by adding 
a section to be known as Section 8, Article VIII coverirg Destructive 
Price Cutting was made but Code Authority officials state this was 
never pressed to a conclusion. 

The minutes of this meeting are not apparently* - in our own files, 
but the following was taken from the Code Authority Minute Book. 

"Proposal to amend the Code by adding a section to Article VIII 
to be known as No. 8. 

."Destructive Price Cutting "oy means of covering any metal 
center frame, pocket and coin purse with fabric materials or 



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leather, or the lining of any f rarnepocket 
or purse with leather in handbags selling 
at less than $24. 00 per dozen is unfair 
competition. " 

Earlier in this history it was pointed out that manufacturers having 
gone as far as they cor Id with competition based upon labor costs, began to 
add gadgets, thus starting a race, destructive of sound practice. The 
above proposal was a first step looking toward the building of a saner 
view point. Naturally the differing view poinf among manufacturers 
themselves offered difficulty in reconciliation and it was decided to lay 
the subject over in the hope that as time' went on ihdustry would come to 
a realization of better manufacturing end selling practice. 

Homework, here as in all other industries where the practice is 
followed, was quite troublesome, although but a relatively small part 
of the industry operated in this manner, viz: handbeading, hgndcrocheting 
handembroidering and until July 1, 1934 handsewing. After July first this 
last was to cease. 

One does not need to enlarge upon the indecencies existing in this 
character of industry, nor the diffiuclties surrounding attempts to 
govern it. Labor insists it cannot be done and therefore should and must 
be outlawed, which is easier said than done. 

The Code Authority and its Directors made great effort to meet 
the situation and presented to the A&ministretion a rather comprehensive 
program looking toward at least a partial attempt to bring decency and 
order into being. 

In the files of the Legal Division there is a copy of a tentative 
amendment to Section 8, Article IV for the purpose of establishing a 
commission which shall establish minimum piece work rates for handbeading, 
handcrocheting and handembroidering. This is dated June 28, 1934 and sets 
up that "no member of the industry shall compensate home workers at less 
than the piece work rates established by said Commission, aaid Commission 
shall establish piece work rates which shall be equivalent to a minimum 
hourly rate of 25^ for workers continuously engaged. Said Commission shall 
be supported by members of industry engaged in the manufacture of handbags 
by means of handbeading, handcrocheting and handembroidery, such members 
of industry shall contribute to the support of said Commission by a method 
of assessment to be approved by the Administrator," 

There is to be found in Exhibit a rather comprehensive brief and 
other documents covering the subject and a discussion of it on pages 123 to 
132 Transcript Hearing of February 28, 1935. 

June 21, 1934 the Code Authority passed a resolution adopting the 
report referred to in the preceding paragraph and instructed the Director 
to prepare the necess- ry resolution and forward to the Administrator. ( Minutes 
meeting !T , 12, page 2, June 21, 1934) 

While these minures are not definite as to the intent of the Code 
Authority with respect to preparing an amendment to the Code, it was so 
intended and the matter came up at the Public Hearing adjourned from 

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June 7, 193- , to July 10, 1934 and reference to it is to be found in 
pages 339 to 413-447 to ^52 and in the supplement (complete) of the some 
hearing. 

Labor strenuously opposed the proposal on two grounds first, home 
work in any form is iniquitous and cannot be controlled and second the pro- 
posal set up en hour rate of pay lower than called for in the Code. 

A representative of the Women's Bureau, Department of labor also 
appeared in opposition, particularly with respect to the so called "myth- 
ical rate of 25y* per hour" proposed, and on the further ground that their 
records and investigation showed, that many of the skilled home working 
women were earning a rate higher than that, further that home work 
cannot be policed and ought to -be abolished. (Pages 374 to 379 Transcript ; 
Public Hearings July 10,~1934) 

The matter never reached a conclusion being more or less interwoven 
with the entire labor provisions, nevertheless the Code Directors made con- 
sistent effort to bring abo\it a better state of affairs. 

February 7, 1935 notice of hearing was p\iblished(No.-367 -F) 
and the hearing tool place before Colonel Walter Kiangum, Deputy Administrator, 
February 28, 1935 to consider the following proposed amendments: 

--article III Section 2 shall re; d as follows: 

"No person employed in shipping, clerical or 
of- ice work, unless he is employed in a man*^ 
agerial or executive capacity and ea.rns not 
less than thirty five (335.00) dollars per 
week, shall be permitted to work in excess of 
forty (40) hours per week averaged over any 
one month period, provided, however, that a 
pe.rtner, officer, director, or stockholder or 
a member of the industry enhoyed in productive 
labor, shall be considered an employee for 
the purposes of this Code, and shall be subject 
to the labo r provisions thereof". 

Article VI Section 8 (c) shall read as follows: 

"Each member of the Industry shall keep accurate 
and complete records of his, their or its trans- 
actions in the industry in respect to wages, hours 
of labor, conditions of employment, . number of em- 
ployees and other matters necessary for the ef- 
fectuation of the Code, and Title I of the National 
Industrial Recovery Act. E a ch member shall furnish 
accurate reports based upon such records covering 
such matters when reruired by the Code Authority 
or the National Industrial Recovery Board.. If the 
Code Authority or the National Industrial Recovery 
Board shall determine that doubt exists as the 
acctiracy of any such report, so much of the per- 

9811 



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tinent books, records and papers of such member 
as may be required for the verification of such 
report may bo examined by an agency agreed upon 
between the Code Authority and such member, or in the 
absence of an agreement, by an agency appointed by 
the Code Authority and approved by the National In- 
dustrial Recovery Board. If a member of the Industry 
shall fail to furnish accurate reports, covering any 
of the foregoing matters when required by the code 
Authority or the National Industrial Recovery Board 
such member shall make available to an agency 
appointed by the Code Authority with the approval 
- of the National Industrial Recovery Board so much 
of the pertinent books , records and papers of such 
member as may be required by the Code Authority 
with respect to wages, hours of labor, conditions 
of employment, number of employees and other matt'ers 
necessary for the effectuati m of this Code". 

Article VII Section 11 to read as fallows: 

"No member of the industry shall grant cash 
discounts in excess of 3/10 E, 0. M. Exception on 
goods sold up to and including $27.00 a gross, no 
members of the industry shall grant cash discounts 
in excess nf:2/l0 E. 0. M. Anticipation may be allow- 
ed at the rate of 6$ per annum. No member of the 
industry shall grant quantity and/or volume discounts 
of any nature". 

Add a new section to Article VIII to be known as Section 16 to read 
as follows: 

"Free Deals - Combination Deals no member of the 
Industry, shall directly or indirectly give what 
are known as 'free deals' or 'free merchandise 1 
or 'combination deals' whereby a joint total price 
is charged for handbags along with other merchandise 
All bills and invoices in which handbags are one of 
the items, shall set forth separately and definitely 
the charge of the handbag alone". 

Neither of these Amendments were ever approved and were still "in 
process" when the act ceased. 

In an earlier chapter mention was made of strife within Union Ranks 
resulting in a complete overturn of officer personnel. 

The most colorful of these officials, the mest persuasive left Union 
ranks to take ch-rge of Labor Relations for the then largest manufacturer, 
Morris White later Stylecraft Bag Company at a salary of $52,000 per annum. 
He later rejoined Union ranks and after the break in his Union decided to 
open a factory, financed and operated by men of the craft and fellow union- 
ists. Each of the men underwrote a portion of the capital needs, and each 

9811 



-74- 



o.:c: ;.. ;a a."' ice" of ifis company and the shop "as conducted as a coopera- 
tive. Still others did likewise and the industry -:. r as faced "ith a 
breakdown of hour schedules by the subterfuge of men- claiming to be com- 
pany officers. Hence the purpose of the first oroposal. 

Again in an earlier cha Dter it is pointed out that this industry 
was not statistically fact minded', nor realized the value of such material. 
The Code in its approved form was not adequate, not as explicit in this 
respect as it might have been, making it difficult to obtain necessary 
pertinent information. It was felt this oroposed. change was necessary. 

A change "as pending in the set up of this Code's definition, also 
negotiations for a consolidation of a Troup that had oeen "oart of the 
Luggage Industry ', ith the Handba; Code Authority had been about concluded. 
In that group selling terms had been established and without change for 
many years. It "as necessar 7 ' that the -rooosed amendment respecting 
terms be brought be p ore the Administrator for approval. This served, to 
reopen the "hole euestion of Discounts - see pages 19 to 03 of Transcript 
of Searing, 7ebraar~- 23, 1933. 

The 7ree Deals - Combination Deals proposal wo.s felt necessary be- 
cause of the rrowing demands by retailers for all sorts of free things, 
initials for example. It was but another form of "hirping the devil 
around the stump. See pages 83 to 86 of the Transcript Public .Tearing, 
February 38, 1935. 

In concluding this chapter it is ' ell to state that the t"o amend- 
ments aoproved and those proposed hc<6 a tooc effect upon industry. It 
vr s made known to ind.ustr - ' by xiblication and "ord of mouth, "hat the 
Code Authority '." r a.s doing and there cane about a fe j lin.: that their Code 
Authority was on its toes, tackling troublesome -oroblems in a painstaking 
thoughtful manner. All did not agree in detail with conclusions reached, 
out it was felt and believed that right thinking had. been developed with 
a quieting stabilizing effect. 

2. I nt e i-o re tat i on s 

(a) There pas out one interpretation made under this Cod.e 
(Administrative Order i< T o. 332-10), dated June 6„ 1934 signed Earl Dean 
Howard, Deputy Administrator and Sol A. Rosenblatt, Division Administra- 
tor, Division To. 5. ' (See 3;chibit S.) 

The question raised was that of the inclusion of a certa.in 
process of manufacture, the linking together of numerous pieces of lea- 
ther, under the term "hand crocheting". Could it Iipvq been so included it 
followed that under Section 10 of Article V, such work v ;ould have been 
permitted in the home. 

Since the interpretation d.id not include it under "hand 
crocheting" it became a process forbidden for home work. 

(b) Effect on Industry 

I believe some euestion was later raised as to the sound. - 
ness o p this coinion. Some thought it a rise thing to have included it 
9811 



-75- 

iinder Hand Crocheting, it being a natural operation for home work. On 
the other nand it is difficult to see how by any stretch of the imagina- 
tion it could be considered as "hand crocheting" or as coming under such 
a general heading, for it is a totally different process. 

(c) Discussion of Value 

The Order is explicit end there seems no furtner comment 



needed, 



Exemptions and Stays 



I' T o exemptions " r ere granted imder this Code. The minutes of Code 
Authority meetings and our orn general files, contain many references 
to, and f "orjlications for exemptions and permissions to ,- ork overtime, 
enrolo 1 - learners, wa~e differentials, particularl'" - a Southern rate, ap- 
prentices, snd to rori: two shifts, but the Code Authority rejected all 
such on the broad general ground that conditions in the industry did not 
warrant approval. 

One -oublic hearing ras held ilay 7, 1934, (Ho. 367-A) , unon ap-olica- 
tions for exemptions by:- 

Hudson Leather Goods Co., Inc., Nyack, N.Y. exemption Art. Ill, Sec. 
2, and for lermis^ion to employ learners in accord vith Article 17, Sec- 
tion 3. 

G. R. Godfrey Company, Gardner, iiass. Exemption -from Article III, 
Section 1, and Article IV, Sections L and 6. 

Paraxon i- T ovelty Bag Co., Inc., 
Uneeda Belt Co., Inc., 
Kewberg Handbag Co., Inc., 
Licht & Kaplan, Inc., 

all of Hewburg, H« Y. Exemption from Article IV, Section 1 and to em- 
ploy learners, Article IV, Section 3. 

Strand Leather Goods Co., Inc., Hew York, II. Y. to employ learners, 
Article IV, Section 3. 

Virginia Art Goods Studio, Inc., 
L;rnchburg , Vi rgi ni a . 

'.'."age Differential. 

Under ord_ers 332-4-5-6- and 7, signed by Earl Dean Howard, Deput^, 
all of these petitions were denied except Virginia Art Goods Studios. 
The situation rurrounding Virginia Art was always difficult and somewhat 
beclouded. Virginia claimed exemption within ten days after approval of 
the Code, in that the]/ '..ere not parties to it. The Code Authority pointed 
out their membership in the major sponsoring organization and failure to 
resi~n made them parties to the Code. In the public hearing of May 7, 
1934, the^ were permitted to file briefs. As far as the files disclose, 

9811 



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action was witheld on their petition, all others heard being denied. 

No evidence c<?n be found that formal action was ever taken unon 
Virginia Art but it is clear that a tacit approval to exemption was 
given. This gave rise to much bitter criticism by the Code Authority 
vzhich flared uo rather badly '"'hen in July 1934 it was nade known that 
a further hearing -as to be opened. Nothing definite came from this and 
the matter dragged along all through fall and winter of 1934 and 1935 
with, at almost every Code Authority meeting, bitter resentment being 
voiced over the fact that Virginia Art ,r ere operating in their own way 
without regard to Code reauirements. The Code Authority insisted that 
undue influence had been and was being ezercised, and found themselves 
in a difficult untenable position since the case -as constantly used as 
an example by offenders in extenuation of their own misdeeds. The Code 
Authority and its Directors felt the T - could do nothing and it was not 
until Deputy Colonel 1'iangum and his assistant Danf Hill took hold, that 
successful steps were taken to iron out the situation. Through the 
good, offices of the Deputy, the Code Director, :.ax Berkowitz proceeded 
to Lynchburg end made a study of operations. He made certain recom- 
mendations with respect to plant operations and the installation of a 
cost system and found evidence of the ability of Virginia Art to pay 
code wages. Reference to Exhibit A. 1. portion dated April 20, 1935 
gives indication of the success attending thel as t, as well as a history of 
the case. 

4. Other Administrative activities and agencies 

a. Trade Practice Complaints Committee 

On September 27, 1934, Order No. 332-17, a plan of organi- 
zation and procedure covering Trade Practice Complaints and the appoint- 
ment of a Committee was approved o _r the Administration. The personnel 
of the Committee consisted of the following: 

killiam C. Hath, President 

"Jilliam C. Path Co., Inc., 

31 last 32nd Street, 

Hew York City. 

New Yor 1 " Manufacturer making bags ranging in 

retail price from $1.95 up to and over $4.95. 

Hyman Burstein, President 

Charles Burstein & Bros., Inc., 

325 Fifth Avenue, 

Hew York Cit-'. 

An out of town manufacturer making bags ranging 

in retail price from pi. 00 to $4.95. 

iiax '..arschauer, President 

Max Vierschauer, Inc., 

58 .'est 32nd Street, 

New York City. 

A beaded bag manufacturer of N. Y. City. 

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-77- 



Laurence LIoss, President 

Enterprise Accessories, Inc., 

353 Fifth Avenue, 

Ne 1 " York Citv. 

A Few York Manufacturer making a one price line 

to retail at $4.95 

Application for approval of this committee was first made 
under authority of a resolution passed b" the Code Authority at meeting 
Fo. 4 held April 11, 1934 (see liinutes in inhibit 3.1) but it '.'as not 
aooroved until the following September and the conmittee held but one 
meeting, October 9, 1934. 

There was also submitted, at that time a plan of procedure, 
which with some change was also approved (Exhibit B.l). The plan called 
for a National Committee as '"ell as 'tegional Divisional and aibdi visional 
committees for specified territories and purposes. 3ut one committee, 
the National, r/as ever set up and for reasons stated beloi- never actually 
functioned. 

The ;oaid personnel of this Code Authority held a broader view- 
point of their functions and their opportunity to serve, than was the 
case in other industries, coupled with, as ex-manufacturers of handbags, 
having a primary knowledge of their industry, its problems and pitfalls. 
It v/a.s in their viev; point, right and proper to take up all compliance 
matters themselves, '"ere they tra.de practices, or hours and wages, study 
each situation, apply any remedy necessary and report to the whole Code 
Authority. 

. .' -At no time within the knowlud£o of thewriter were trade prac- 
tice complaints made at first hand, knowledge of seeming violations corn- 
in: to officials, as a result of study of the retailer' s buying and 
selling of merchandise. Having obtained in this way, frets upon which 
to act, meetins '-ere had with the parties involved and it was generally 
found that violations occurrec 1 through lack of proper understanding and 
were readily straightened out. 

(b) La.bor Complaints Committee 

At a meeting of the Code Authority held June 14, (ifeeiing No. 
11, see i'inutes Exhibit C-l) a resolution was passed appointing a National 
Labor Complaints Committee consisting of three members of industry, and 
also that the Labor Advisor^ Board should appoint three members and that 
the Admini strati on Member should be a member. The following indust^ 
members were appointed: 

David A. Ingber, President, Ingber Co., Inc., 

347 Fifth Ave., New York 
David Morgenstern, President, Morgenstern & Brossear, Inc. 

26 No. 17th St., New York 
Sol Hutterperl, President, Sol l.iutterperl, Inc., 

330 Fifth Avenue, New York, N.Y. 

The names of this committee, together with plan of procedure was submitted 
9811 



-78- 



to the Administration July 6, 1934, but never approved and therefore did 
not function. 

(c) 3y-L3,ws 

By-Laws (See Exhibit D.l) Here first submitted June 28, 1934, 
having been nassec* by the Code Aughority iieeting June 14, 1934 (See min- 
utes meeting No . 11, General Files.) 

NATIONAL P.EC0VSRY ADMINISTRATION 

WASHINGTON, D. C. 



45 Broadway 
New York City 

Digby 4-2324 June 28th, 1934 



Mr. David Barr 

Assistant Deputy Administrator, Div. V, NRA 
Department of Commerce Building 
"Washington, D. C. 

Dear Llr. 3arr: 

SUBJECT: Constitution and by-la'" s of the Ladies' Handbag Code 
Authority 

I transmit herewith for your approval three conies of the constitution 
and by-la 1 's for the Ladies' Handbag Code Authority. I have gone over 
these carefull"" - and see nothing ocjectionable in them. However. I am 
wondering if it i r> not -ooar-ible for taece r .n d all other by-lrws to 
induce a -provision clearl Tr statin:-- tne duties of the Code Directors . 

I merely make this suggestion because of the habit Code Authority mem- 
bers-have of hiring and firing regardless of a Code Director. 

I have upon a number of occasions at Code Authority meetings emphasized 
to members, the necessity of placing full responsibility upon the shoul- 
ders of their Chief Executive Officers and that this cannot be done un- 
less they refrain from foisting upon the payroll of the Code Authority 
their own peculiar pets, or appointees. This situation has existed in 
Millinery ever since they first opened their office and it is one I have 
not succeeded in righting. 

Yours sincerely, 

(Signed) 0. '.7. PEARSON 
0. *.". PEARSON 
0WP:DAR ADI II NI STRATI ON MEMBER 

9811 



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By-Law s ( c on t i nue d) 



Mr. Max Berkowitz 

Ladies Handbag Code Authority 
303 Fifth Avenue 
New York City 

Dear Mr. Berkowitz: 

I am enclosing here-'ith a cop-' - of the By-laws 
of the Ladies Handbag Industry Code Authority with 
suggested revisions to meet the objections of the 
Legal Division. 

Your attention is called to the following changes: 

Article III of the original, has been deleted. Cer- 
tificates of Compliance are provided for in Adminis- 
trative Order X-38, dealing with le.bel regulations. 

Article IV, Section 1 has been amended by the insertion of 
the word "Industry" before the word "members" in the 
third sentence thereof. 

Article IV, Section 2 has been amended to set forth 
the provisions of the Code with reference to the 
method of election of the Code Authority. 

Article IV, Section 4 has been amended by the inser- 
tion of the "ord "Industry" before the words "iiember- 
ship" and "Representatives". 

Article V, Section 4 has been amended to make provi- 
sion for the posting of a bond by the treasurer. 

Article VII, Sections 1 and 2 have been deleted, and 
the -orovisions of Sections 1 and 2 of Article VII of 
"Suggestions for By-Laws for Code Authorities (Re- 
vised edition) have been substituted. 

Article VII, Section 3 has been revised to conform 
to the "Suggestions". 

Article VIII, Section 3 has been deleted. Itemized 
budgets must be submitted annually to the Administrator. 
T.'hen so submitted a separate approval of the Budget and 
Plan of Assessment may be given by the Administrator. 

If these By-Laws, as revised, are satisfactory 
will you kindly forward, as soon as possible, six 
copies of the certification of their adoption by the 
Code Authority. 

Very truly yours, 



David Barr 
Assistant Deputy Administrator 
9811 Apparel Section 



-80- 



?or some reason not disclosed this matter was dormant until October 
1934, -Then on the fifth da" of that month the amended by-Lavs were re- 
submitted end approved under Order 332-19. 

(d) Other 

There were no peculiar administrative actions or agencies 
utilized. 

5 . Other -phases of Core Administration not covered above . 

A Trade Association of concrete positive value has been unknown in 
this Industry except perhaps the one dealing onlv with collective agree- 
raents. Just wiry they etisted even in name is hard to understand, for not 
being herd minded so to speak, this industry would not adequately support 
a forward looking activity of this character. 

The hand bag Code Authority di re c to rate Tien t far afield in their 
work, appreciating the need of building a closely knit industry, cement- 
ing relationships between sources of supply and their own group, and be- 
tween wholesalers, retailers and themselves. They kept close watch upon 
advertising of offerings by retailers, both regular and special, kept 
closel - "- in touch with fashion, style and color trends, constfntly met 
with trade association executives and leading men of industry, clocel" r 
allied to or impinging upon their own, for these men having a. vision, 
realized how much might and could be accomplished under their Code set 
up. 

The Code Authority itself while appreciative of the value of such 
work when told of it, could not carrv on, were not mental!"' - geared to 
it, and without the leadership of men such as the two directors, would 
never have thought of such tings, least of all realized their need. 

Given another year of operation this group would have found, itself, 
would, have known itself, would have intrenched itself, would have become 
fully conscious of their need of such knowledge and. of the unity that 
springs from it. Evidence in the Code Authorit- r files clearly indicate 
the gains made. 



9811 



-81- 



OPERA.TION OF CODE PROVISIONS 



Latior Provisions 

Hours 

Wages 

Administrative Provisions 

Trade Practices 



9811 



-82- 

IV. OPEPATION OF CODE PROVISIONS 

A. Definitions 

As stated in Section a, Chapter One of this history (.Page 3). 
the following definition included in the approved code left something 
to be desired for constant requests come in for clarification. 

"The term 'industry' as used herein includes the manu- 
facture of ladies', misses' and childrens ' handbags, 
pocketbooks, and purses, manufactured of any material 
of any kind or nature. The term 'industry' shall not 
include, however, the manufacture of handbags, pocket- 
books, purses and mesh bags manufactured in whole of 
metal. " 

1. Overlappin g 

The trouble lay in the fact that many articles falling generally 
into the handbag category, were made by t-ro other industries not con- 
sidered as handbag manufacturers viz:- Sanitary and Waterproof 
Specialties Industry and Luggage and Fancy Leather Gk>ods Industry. 

As the first named title indicates, that group were producing 
many articles that because they were made cf waterproofed materials, 
naturally fell into their -nroduction line, and yet which to a degree 
belonged to hand bags, since they were designed to be carried in the 
hand for various utility purposes, "/aturally such manufacturers did 
not wish to operate under more codes than necessary and opposed their 
inclusion under Handbags, .and it became necessary for the Ladies' 
Handbag Code Authority to move for an amendment. 

The problem with the second group was involved with both Sanitary 
Specialties and Handbags. Almost since time began women have used 
some form of a reticule in which to carry their small belongings, money, 
etc., and the controversy here narrowed down to the dividing line 
between hand luggage and hand bags. 

The feeling on the -nart of the Deputy Administrator indicated at 
the public hearing January 9, 1935 was that Handbag and Luggage Code 
Authorities should get together and agree upon the division, with 
perhaps a consolidation of the two, so closely allied industries, as 
being the best answer. In the case of Sanitary Specialties the 
Assistant Administrator made the ruling referred to on page 86 this 
hisotry. The amendment proposed was in process of settlement at the 
close (Notice of Public Hearing No. "67 D.) but in the meanwhile the 
officers of the Code Authorities involved, agreed upon a modus Vivendi 
that kept affairs moving on an even plane. 

In future consideration of codes, should that time ever come, 
greater care must be taken in scrutinizing proposed definitions and 
see that each is properly embracing, but at the same time determining 
where and what are dividing lines. These cannot be determined satis- 
factorily in industries such as these, upon merchandise departments in 



9811 



the retail outlets, for there, they either follow custom of their own 
convenience. Here you are concerned with production and all that is 
involved therein, and such must be kept upon a fairly even cost plane. 
To do otherwise keeps the labor not boiling and of course makes for 
friction and trouble on the labor side, and can well make for destruc- 
tion of a well established industry. Perhaps an answer is to be found 
in minimum wages and hours being made similar in all closely related 
industries. That at least would eliminate much of the controversy 
that takes place in all such cases. In this last, one cannot of course 
overlook the difficulty involved, and yet so long as an uneven situation 
exists, troubles with related industries arise and are magnified and 
since you are bound sooner or later to have trouble over these matters 
you might just as well take the larger dose at the beginning and have 
done with it. 

3. Wages 

1. TTage Levels; Minim?, Average '" ' 

Section 1, Article IV, page 31- of the code states that "except as 
hereinafter provided no employee shall be paid at less than the rate 
of thirty-five cents (Z5/£) nev hour." 

Section 2 of the same article states "that no semi-skilled 
employee engaged in cutting, framing, paring, pocketbook making and/or 
operating (-except lining operating, cementing and/or posting) employed 
in the manufacture of any of the products covered by the provisions of 
this Code, made of any materials other than imitation leather, shall 
be paid at less than the rate of forty-five cents (45^) per hour." 

These are the only two rates of pay provided and since the last 
was stayed in the order of approval we need only at this point be 
concerned with the first named. 

Exhibit G, page 1, paragraph 2; page gi paragraph 2; page 4, 
paragraph 2 of the Mittenthal memo on the industry, gives a picture 
of the wage situation obtaining prior to the code. 

Exhibit F gives a statistical break-down of present day distribution 
of the industry, disclosed in Code Authority reports. 

If, as claimed by out of town manufacturers, the large majority 
of their employees were not skilled, the effect of the code wage scale 
in increasing purchasing power, must have been very marked, for they 
jumped from an average of $6.00 to $8.00 per week, to a minimum of 
$14.00 weekly. 



Taking the manufacturers statement in this respect, with a large 
grain of salt, ray own observation 'of processes used in out of ' town 
factories, leads me to conclude that a full 50^ of those engaged were 
definitely affected by this increase, and the classification break-down 
included in Exhibit F bears this out. 



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•84- 



2. Industry Compliance 



Of the 87 labor complaints made, but 37"$ were of wages, and well 
over 50$ of these from one state Massachusetts. See Compliance 
Compila'tion by Colonel Walter Mangum. (Also see Exhibit R.) 

3. Skilled Wages 

Section 2 referred to in Paragraph one of this chapter was as 
n»ted, stayed, in the order of approval. As pointed out in Chapter 
2, page xq' of this history and as may further be seen by examination 
of Exhibit K, much time and effort was spent upon this subject and all 
without avail. It was a compromise clause placed to placate labor 
and Few York Manufacturers, and in the hope, that from it, would come 
a substantial increa.se in earnings to a fairly large number of employees. 
Coupled with it was section six providing for a permissive classifi- 
cation and basic rates for the more skilled classes of labor. 

Exhibit G, pages 1-2—3 and 4 gives concisely the labor situation 
obtaining in the industry prior to the Code's adoption. 

4. Adjustment of wages above the minimum 

There were no provisions for an upward adjustment of wages. 

5. Ma 1- Ad j u s t me n t with other industries 

In paragraph A, page 82 cf this chapter, reference is made to 
the difficulty existing between the Sanitary and Waterproof Specialties 
Manufacturing Industry, Code ITo. 342 and the Luggage and Fancy Leather 
Goods Industry Code No. 42. 

The Luggage and Fancy Leather Goods Industry Code provided for a 
differential in the Southern tier of States of 32 l/2 cents for male 
and 30 cents per hour for females as against 35 cents for male and 32 1/2 
cents for female in the Northern States. It also made provisions for 
learners to be paid during a six weeks period not less than 80$ of the 
minimum. 

The Sanitary and Waterproof Specialties Manufacturing Industry 
Code made provision, that the rate be 35 cents per hour, except that 
Apprentices be paid not less than 28 cents per hour for the first six 
weeks and thereafter at 35 cents per hour. 

The Ladies Handbag Code provided a rate of 35 cents per hour, with 
no exceptions and a permissive clause for learners with no specified 
rate. 

Obviously when questions of jurisdiction over certain products 
arose as they did, these rates became disturbing, and more especially 
with Luggage for it was felt that that industry had not an efficient 
Code Authority machine set up. 



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-aD- 



As pointed out in Paragraph A mentioned above, the matter was 
being adjusted by way of a definition amendment at the close. 

6. Posting of Labor Provisions . 

Industry complied 100"$ with the -posting of labor provisions with 
this, to be exoected curious result. Certain out of town factories 
concluded it would b'e wise to come to an agreement with the union, 
but somewhat uoon owners rather than union's terms. Rates of nay 
were agreed to but collection of union dues was made in the office of 
the factory and union officials denied access to factory floors. In 
the last month of code life employees were becoming restive at paying 
union dues, stating they could not see any good reason for so doing, 
since it was the code and not the union that was responsible for the 
pay envelone increase. What the outcome of this unrest would have 
been it is hard to say. The factory owners, while not anxious to have 
dealings with the union, felt the pressure of insidious -propaganda 
made by unions, and therefore insisted with their employees, that 
their union agreement was -oolitic and wise. 

7. Insignia 

Since this was a label industry all merchandise carried the 1T.R.A. 
insignia and it was extremely difficult for a manufacturer to dispose 
of his product without a label. Of course he was not -permitted to 
have labels, if he were not in compliance. 

C . HOURS 

1. Effect of Code on Industry 

The figures from various sources concerning total employment in 
the industry are at wide variance so that it is impossible to say what 
effect shortened hours had uoon the industry. Ranging from a quotation 
of 15000 (See Exhibit F, page •§) it is to be noted that the Code 
Authority's monthly reports from industry (Exhibit P) show but a-p-proxi- 
mately 6000, exclusive of employers and salesmen. Of course these 
reports are not complete, and since they are not, it is difficult to 
come to any conclusion uoon this point. Industry itself repeatedly 
said to me that shortened hours had increased employment but' not to 
any great degree. Repeated requests were made for -permission to work 
two shifts and for overtime as well as for learners but the Code 
Authority refused them all without exception, on the ground conditions 
did not warrant. Here again migration from New York had a bearing. 
Almost all of the moved factories had relocated themselves in smaller 
centers, where no. labor, or at least but a small number, of a skilled 
or -partially skilled character was available. (Using the term skilled 
here, is of course, meant, those familiar with or used to factory work 
of any kind). It follows therefore that it was difficult to find 
necessary man power to loroduce work at the -peak seasons of Easter and 
fall and early winter, hence I do not believe much increase in the 
number of -people put to work was made. 



9811 



-86- 

2. Effect of Tolerances, peak -period provisions, various 
differentials . 

There were no tolerances or differentials provided for in this 
Code. The West and South were desirous of them but the provision 
was not included and industry, taking it as a whole, set their face 
against them. Reference is made to Exhibits V and W to illustrate 
reasons and position taken by the Code Authority. 

3. Industry Compliance 

Reference to compliance data gathered by Colonel Walter Mangum 
and the Compliance statistics of the Code Authority contained in 
Exhibit F and also those in Exhibit R shows that compliance with hours 
was uniformly high. Labor was insistent that the hour provisions 
should be amended wishing to reduce them to 30, but that of course was 
consistent with their position in all of these industries and was felt 
not to be sound. At any rate- nothing ever came from the demand. My 
own feeling was and is, that such a step would have been disruptive 
and would have defeated the purpose of putting more people at work, 
for I do not believe industry could have adjusted itself to such a 
radical change. After all it was a step forward to bring about the 
reduction that was made, and one needs time to absorb what is involved 
even in a first step. 

4. Mai-Adjustment with Other Industries 

There was no mal-adjustment with respect to hours. 

5. Posting of Hou rs provisions 

Labor provisions were posted as noted in paragraph B, section 6 
of this chapter. 

6. Insignia 

N.R.A. insignia was used as noted in Section 7, Paragraph B of 
this Chapter. 



D. OTHER LABOR PROVISIONS 

1. Child Labor 

With the exception of one group in Massachusetts and one having 
their products made in the home, child labor was unknown in the 
industry, before or since the Code. In the first group located in 
Haverhill, Massachusetts a rather shocking situation' came to light, 
and it is doubtful that but for the Code, any but local officials would 
have ever known of its existence. This group hit upon the idea of 
manufacturing a type of bag made .by weaving strips of leather. They 
were Greeks and the heads of each family lived by their wives' and 
childrens 1 sweat, This was stopped by the Code Authority. (See Exhibit 
G, P. 225,, paragraphs 1 and 2 also Exhibit X) . Since child labor is a 
constituent part of Home "Work the discussion of the second group is 
carried on in the following section. 
9811 



-87-. 

2. Home Workers 

Home Work has existed for some years in this industry "but mainly 
confined to hand crocheting, hand embroidery and hand beading. Such 
tyoe of work is used in the beaded bag division and was nermitted 
under the Code, but it was further ordered, that in conjunction w ith 
such State and Federal departments and other agencies the Administrator 
might designate, the Code Authority should study and investigate the 
problem of homework, and make recommendations for its effective control. 
Hand Sewing in the home was also permitted but only until July 1, 1934, 
that being considered sufficient time to eliminate the practice. 
(Article 5, Section 10, Code). 

Reference is made on pages 50, 63 shis history to the manner in 
which the Code Directors aporoached the -problem and Exhibit indicates 
their conclusion and their recommendation. The plan was never a-pproved. 
The hand sewing embargo went into effect on the day appointed and was 
enforced insofar as such a -provision is enforceable. 

There are about 25 manufacturers engaged with it is stated 5000 
workers. Of this number it is estimated only 500 are emoloyed in the 
factories. Under the Code 35(£ was to be the hourly rate of nay, set 
for all as minimum, but these manufacturers found it impossible to 
compete with the imported -product on this basis hence their insistence 
uoon a lower rate. 

3. Handicapped Workers 

Article IV, Section 7 reads as follows: 

"A person whose working capacity is limited, because of age 
or physical or mental handicap may be employed at a wage 
below the minimum established by this Code under the follow- 
ing conditions: 

"(a) That they shall be naid -nronortionately no less than 
the other employees in the same factory receive for similar 
work, but in no case ehall their compensation amount to 
less than seventy percent (70^) of the amount required by 
the minimum wage -provisions of this Code. 

"(b) That the employer shall at once -pre-pare and transmit 
to the Code Authority a list of such excepted persons stating 
name, class of occupation, wage rate, length of service and 
reason for exception. This list shall be revised up-to-date 
once each month and transmitted to the Code Authority. 

"(c) The proportion of excepted -persons to total employees 
at any time shall not exceed the nro-oortion of such employees 
on the pay roll during the week of July 15, 1933. 

"(d) The Code Authority shall have the right to investigate 
and disallow any such claims for exception subject to review 
by the Administrator upon an-peal by an employer or employee. 



9811 



— DO— 

"(e) The Co^e Authority shall report to the Administrator 
within three (3) months and from time to time' thereafter 
as to cbe effect of the o-neration of this provision, both 
generally and in cases of individual hardship." 

At a moetii.g of the Code Authority held May 3, 1934 known as 
Meeting No'. C the committee en Handica-oped persons presented the 
following report: 

COMMITTEE OH HAEM CAPPED PERSONS 

A meeting of the Committee was held at the office of the Code 
Authority on April 30, 1934. 

Messrs. L„ Mess, Chairman, and Wm. C. Rath, were present. 

The U. S. Department o'f Labor has issusd certain regulations in 
regard to the employment of "handj"., iped persons" which "by executive 
order of February 17tu are extended to all Codes -previously a-oproved and 
to be ao"oro/ei3 „ 

Pursuant to the^e regulations, an'! in accord;? nee w ith Article IV, 
Section 7 of the Cede, the Ccmnitlne recommends the following: 

All employers who -vish to enioloy handicapped oersons below 
the minimum 7Rge jrae, must folic* this urocedure: 

1. A^r/iication must be made to the S^ate Agency 
designated by chr U. S. Department of L^bor 
for a certificate. This annlica 4 i on must be 
accompanied by tne decoor's certificate. 

2. After the State certificate is obtained, an 
amplication is to be made x,o the Code Authority 
for the employment of such workers 



Respectfully submitted, 
Lawrence Moss 
Chairman 

For some ueculiar reason it arrears that this industry, with the 
exception c^ the homework section, has not \d hand.1 caoned -oersons in 
its workor rank.-, Ebcl -;ng wi tn ref erenow ' • such workers is to be 
found in the fi'es and so far as I can recoil no anuli cat ions covering 
them were ever made to the Code Auu.ority. 

4. Atror entices and Le arners. 

The Cole contains but one reference to learners, section 3, 
Article IV, and that was permissive only for it reads: "The Administra- 
tor may, \:nd°r exceptional circumstances, and upon such conditions as 
he may prescribe, permit a member of r,he industry to employ learners at 
rates below the minimum wage herein established." 



9811 



-89- 

Many applications for permission to employ learners were marie, 
"but the invariable custom was to deny such. The Code Authority were 
desirous of having as nearly 100^ perfection as possible. In their 
judgment learners were not necessary, and the fewer exceptions made, 
the more nearly they "believed would "be the attainment of their 
objective, perfection. This being, so, learners were not and could 
not be exploited. 

5. Other Miscellaneous Labor Provisions 

Section 3 of Article III which stated "The provisions of this 
article shall not apply to outside salesmen" led to considerable 
argument. This group of employees had become quite restive (See 
Exhibit E.l) and wished to be considered in the code provisions, in 
fact outside salesmen in all consumer goods industries were insistent 
upon recognition, organized andapnlied for an A. F. of L. charter. 
The Handbag Industry here refused to consider collective bargaining, 
taking the position that the nature of the salesman's calling was such, 
that of necessity all dealing's must be with the individual. Nothing 
was ever accomplished. 

Article V, Section 2, Right to Organize, standard. 

Section 3 of this article, Not Reouired to Join Company Union, 
also standard. 

Section 4, provided that employers shall comply with maximum 
hours, minimum rates of pay and other conditions of employment approved 
or prescribed by the President. Standard. 

Section 5. Forbiadance of reclassification. Standard. 

Section 6. Providing for safety and health. Standard. 

Section 7. Related to State Laws more stringent than Code 
provisions. Standard. 

Section 8. Providing for posting of Labor Provisions. Standard. 

Section 9. No modification of established practices relating 
to vacations, etc. Standard. 

Section 10. Home work forbiddance except for handbeading, hand 
crocheting or hand embroidering. See Section D, this chapter. 

Section 11. Provided for observance of Code Wages and hours by 
employers in other industries making articles coming under this Code. 

Checked closely and by moral suasion, observed. 

Section 12. Requiring responsibility of manufacturers for observance 
9f code provisions on the part of contractors in their employ, 

Followed and checked persistently. 
9811 



-90- 
E-.- - ADMINISTRATIVE PROVISIONS 

1. Investigation of Records 

Subjection C, sectVn 7, Article VI of the code stated "To obtain 
from nei"p. v er^ of bho Cndustry such Information and reports as are re- 
quire! fcr *ie Administration of the Ci:.rlc t and in addition to information 
required to be submitted to any Cods Authority, all or an?/ of the 
persons subject to this code shall furnish such statistical information 
as the Adu.".ni?tia. r . or ray derm necer -.r.rv f«r the purposes recided in 
Section 3 (a) of the Act, to such Federal and State Agencies as the 
Administrator may designate. 11 

As rioted ir orevicus cba-nters, statistical information was unknown 
in this iniustrj piicr to the Code, and with the exception of two or 
three, the word "statistics" appeared to bo a new term and therefore 
not understocde However bhe Coda Authority Directors took first steos 
to gather such simple frets an possible. 

Exhibit F. gives the extent cf statistics gathered. 

Exhibit N Section dated iferch 13, ] S;*5 also refers to this subject. 

2. Co?-lect ion of Statis tics; Confidential Agency 

I'o outside agency for collection of this material was used, the 
Code Authority preferring the employment of tbeir o^n office staff. 
Such material was kept a" confidential and there were no complaints 
as to leaks. While no definite ^revision for investigation of records 
was made in the 0?de, the CoGe Directors and their subordinates did, 
when they had reason to douot correctness of figures suoolied, examine 
books ajod so far as I know without question of right being raised. 

3 . Li cfj i da t ed Dp -nag e s 

There was not contained in this Code a clause providing for 
Liquidated Damages. 

4. Other 

The other Administrative provisions: Compliance machinery set up, 
writing of constitution and by-laws c >ordination of this with other 
industries, providing of a bnoget and col lection cf assessments, the 
setting up of Fai/i Trade Practice and Planning Agency, the recommendation 
of Uniform Cost System and the study of style piracy are treated else- 
where, also see Exhibits H, P, Q,, Z, 3.1, C.l treating of same. 

F . PRICE AND ACCOUNTING PROVI SIGNS 

Subsection I, Section 7 of Article VI, provided for the recommending 
of a uniform cost and/or accounting system for each division of the 
industry and also in Section 14, Article VIII forbidding selling below 
cost. 



9811 



-91- 

The Code Authority officials spent much time and study on this 
phase of activities, without an approved final result being obtained 
and it cannot be said that this matter was the cause of controversy 
for all hoped and looked for such a system. It was, however, found 
extremely difficult to work this out satisfactorily, and only toward 
the end of the code -oeriod was a definite recommendation made. 

On pp. 225 paragraph 4, Exhibit G- the Code Director remarks 
"the average ladies handbag contains about twenty different materials 
and requires about thirty man operations to complete. A general 
lack of knowledge of computing costs by the manufacturers in the 
industry has resulted in ruinous comoetition" which exolains the 
difficulty in working out anything a-nproaching a workable system. 

Exhibit P was forwarded to the Administrator for approval 
December 26, 1934 and February 18, 1935 Or ton W. Boyd of Planning 
and Research filed a memorandum, made part of th: s exhibit. It will 
be seen that as set up, the formula was in some respects contrary 
to Office memorandum 228-3 and in others not considered good 
accounting practice. Many conferences between Mr. Boyd and the Code 
Directors were held but like so much other good work this was never 
carried to a final conclusion. 

1. Price Filing 

There, was not any provision made for filing prices but an attempt 
was made to set price groupings (See Exhibit Z.) At meeting No. 8 
held August 2, 1934 it was decided that the subject matter of Exhibit Z 
be taken up with retailers interested. Since minutes in our files 
disclose nothing further en this matter it is to be -oresumed it lapsed. 

a. Waiting Periods . 

Not provided for. 

2. Emergency Price Bases 

Not provided for. 

3. Accounting Systems or Cost Systems 

Submitted but never approved (See Section F this chapter). 

4. Administrative Price Policy 

Admitted to be desirable and necessary but since system 
submitted never reached final approval did not become operative. 

5. Classification of Customers t 
No code provision 

6. Price Differentials 
No provision. 

9811 



-92- 



a. Sto-Q Loss Provisio n ■.--•■••.• . 

II o pro/ision* ' ■ i 

7. T erms of Paym ent 

Section 11 of Article VIII provided for cash discounts not in 
excess of S/IO-'JE G/:.l. and anUcinatu-n at the rate cf six percent- ' ■: 
(6^) per annum. 

When it became known to *"he outside world that the industry had 
such a provision in the new code s the war was on, and never ceased to 
rage ; during the months r;ec?^ ing and succeeding the public hearing 
of December 8', 1933. Liter. anTyrovnl. the fight eas reopened by the 
National 1 . Retail Try Goods Associations .representative I'r. Fox at every 
opportunity, but • i ndus Cry stirk to its g^ns arid found no great difficulty 
in getting end holding the retailers observance.. Naturally the first 
few'weeks Piter auproval were diffici.lt and all sorts of ways were 
devised to change the intent but without any gre?t success, and as the 
months went by the ne 1 *' ft ;: r .s pe™e an .;.. ; c e-p f ?d commonplace. Fages 24,- 
33, S4, 40 cf this history., tell ti story of the controversy and 
Exhibit g, p p i ojS par-, 1, als< op 226. ^J. 1 r. 2, and Exhibit H state 
the hist*- and argument supporting the industry's position. 

^ oerat ives • 

.. firovition for such. 

G. TB ADE P RACTICES 

1. Class A Trade Practices 

Trade Practices of this Industry were e< bodied in Article VII of 
the Code, as originally aporc .. -d, and a new b'ection 16 was approved 
under Administrative Order 332-24, i-ay 23, i935, which of course .never 
became effective. 

The Section 16 proposal was as follows: ..-..-■-.• 

"No member shall repair any used- ba? -unless a minimum charge 
of 25{£ per bag is made to cove., ice cost of materials and the 
labor on such repair. Nc member 1 - of the* -indus try shall pay. 
for any of the forwarding charges on such repair." 

Section 1 of this Article read: ■ 

"No member of the industry shall publish advertising (whether 
printed, radio, display or of any other nature), which is mis- 
leading cr inaccurate in any matr-rial particular, nor shall 
any m? nber, in any way misrepre ?6nt any goodi, (including but 
without limitation its use, t\ : . .,■ -a-..c, gj.-s.de, quality, quantity, 
origin, size, substance, character, nature, finish, material con- 
tent or preparation) or credit terms, values, policies, services, 
or the nature or form of Che business conducted." 

9811 



-93- 

This industry is not advertising minded, for as far as known there 
is but one, a high style house, who spends advertising money. 
Therefore there was no trouble in this direction, except upon the 
retail side, and over this the .Code Authority could not exercise 
control. Even here, however, realizing a bad effect if allowed to 
continue, the Code Directors brought pressure to bear uoon the of- 
fending store's management and succeeded in checking it. 

With respect to misrepresentation, however, there was occasionally 
another stcry. The Directors using corrective rather than punitive 
measures brought about meetings between buyer and seller so that 
such goods were withdrawn or properly described in their selling. 

An amusing instance of misleading labeling, or marking with intent 
to deceive, was discovered shortly before expiration. One bag item, 
carrying a patent registration number tag, was noted in a. retail 
store. The Directorate .familiar as thev were with their industry, 
knew nothing new under the sun of a patentable nature, had been de- 
veloped for manv years. Note was made of the registration and on 
an early visit to Washington, call was made at the Patent Office. 
There, it was learned, the registration covered a patent issued some 
fiftv years earlier. Of course a stop was put to use of the fradu- 
lent label but for a period, the manufacturer had succeeded in keep- 
ing ever"- one else off his particular grass. 

Our own. files carry nothing covering such matters as this, but refer- 
ence was had to the Code Authority files in New York as well as to 
the Code Directors. 

Section 2: "No member of the industry shall use selling methods or 
credit terms which tend to deceive or mislead the customer or pros- 
pective customers. 

We do not find any record of the operation of this orovision, but 
the writer knows that oressure from retail outlets particularly the 
powerful buying groups was always being exercised to force a change 
in selling terns bv changing the actual prices marked. 

Section 3: "No member of the industry shall withhold from or insert 
in any auotation or invoice any statement that makes it inaccurate 
in any material particular." 

Impossible to check. 

Section 4: "No member of the industry shall brand or mark or pack 
any goods in any manner which is intended to or does deceive or mis- 
lead purchasers with respect to the brand, grade, quality, quantity, 
origin, size, substance, character, nature, finish, material con- 
tent or ^reparation of such goods." 

One notable instance of violation of this provision was gleaned from 
the Code Authority Directors. 

A well known New York Department Store mislabeled and advertised a 
line of bags stating they were of a certain high quality skin. 
Failing to get satisfaction from either the manufacturer involved 

9811 



-94- 

or the store (^imbels) the Co^e Directors took vers the matter with 
the Better Business Bureau and the line was withdrawn with proper 
apologies from the store owner?,, and a tremendous snuawk from the 
manufacturer; 7e however was fiually convinced of his e^ror and 
gracefully a.cceeded. • ■ ._ 

Section 5: "No memher of the Industry shall miblish advertising 
which refers inaccurately in any material particular to any compe- 
titors or their goods, prices, values, credit terms, policies or 
services. " '.•'■. 

As stated in' note commenting on Section 1 of this chapter the indus- 
try is not a'n- advertising industry. 

Section 6: "No member of the industry shall publish or circularize 
unjustified or unwarranted threats of legal proceedings which tend 
to harass or have the effect of Harassing competitors' or intimidating 
their customers." 

There is nothing' in records to indicate any violation of this provi- 
sion neither did I hear of any. Apparently the industry does not 
operate in this manner. 

Section 7: "1Tb member of the Industry shall give, or permit to be 
given any secret ^ayment or allowance of reb-te, refund, commission, 
credit, or unearn> : ] discount, whether in the form of money or other- 
wise, or the secret" extension' to secret purchasers of special ser- 
vices or privileges not extended to all purchasers on like terms 
and conditions." 

rr e have no records covering this but my belief is that it is a pro- 
vision almost, if not quite impossible of checking and therefore of 
enforcement. In meetings with members of Industry, one frequently 
heard the statement that buyers are on the payroll of certain manu- 
facturers. 

Section 9: "No member of the industry shall give, permit to be 
given, or directly offer :to give any thing of value for the purpose 
of influencing or rewarding the action of any employee, agent, or 
representative of another. in relation to. the business of the em- 
ployer of such employee, the -principal of such agent, or the repre- 
sented oarty without the knowledge^ c-f such employer, principal or 
party. Commercial bribery provisions shall not be construed to 
prohibit free and general distribution of articles commonly used for 
advertising except so far as such articles are actually used for 
commercial bribery as- hereinabove defined." 

A provision almost, -if not impossible to check or prove. 'Refer to 
preceeding paragraph. ■' ■' . • ■ . • 

Section 10: "No member of the industry shall attempt to induce the 
breach of an existing contract between a competitor and his customer 
or source of supply; nor shall any member 1 of the industry interfere 
with or obstruct the performance of such contractual duties or ser- 
vices. " ■...-• 

9811 ' :-.:'• 



-95- 

This provision like unto many others has a good moral effect "but 
beyond that does not go. 

Section 13 f orb" de the ora ctice of directly or indirectly naying 
any t>art of the advertising extjen^-e of a purchaser, Prospective 
-purchaser or agent. 

While t. is practice is not so prevalent ps in many other industries, 
Hand 3ag Manufacturers welcomed its inclusion in their code for the 
■practice was beginning to show its head - The -provision was found 
to be s deterrent. 

Section 14 orovided that goods shall not be sold below cost as com- 
muted by the uniform cost system -orovided in Section 7 (i), Article 
VI. 

The cost system was never armroved. 

Section 15: "No member of the industry shall disnose of distressed, 
merchandise exceot uoon -prior notice to the Code Authority, along 
with such information as the Code Authority and the Administrator 
may orescribe. General fall conroetitive items shall not be sold as 
distressed merchandise -prior to December 26, general soring competi- 
tive items shall not be sold as distressed merchandise orior to 
liother-J.s Day, and general summer conroetitive items shall not be 
sold as distressed merchandise orior to July 4. Subject to review 
by the Administrator, the Code Authority may permit the sale of 
merchandise at periods other than those herein established." 

In view of the conroetitive situation this orovision was good, but 
somehow did not seem to work. The entire industry ignored it when 
they believed obliged, and you could not indict the whole crowd. 
Much preaching was done, which in time would have had a good effect, 
in fact there were at the close, slight signs of better thinking if 
not of actual -oractice. 

2. Class 3 Trade Practices 

Section 3 forbade the -oractice of shinning goods on consignment. 

As in many industries, particularly those defiling with dry goods and 
department stores, this is a growing -oractice, one causing serious 
trouble, and this industry desired to nin it in the bud. Argument 
is freouently advanced that consignment -practice gives an oooortun- 
ity to a -producer to more widely distribute his nroducts and a 
broader and auickened movement of his merchandise. Often in hear- 
ings representatives of the Consumers' Advisory 3oard expressed the 
feeling that lower trices and greater buying opportunities would 
accrue to the consumer, and therefore no attempt should be made to 
check or stoo the practice. 

My own and industry's belief is, that sending out consignment mer- 
chandise is a bad practice, one that should not be encouraged, oart- 
icularly with style merchandise for such goods often become obsole- 
cent over night or almost so. 

9811 



-96- 

It is not the function of a nroducer to sell goods to the ultin* te 
consumer himself, he is seldom geared up for it. Such goods need 
selling Find all that th- t word implies. This the manufacturer 
cannot do. If a distributor his his own money invested in merchan- 
dise he has an urge to get 'behind it to get it into his customers 
hands as auickly as -possible, whereas where all the risk remains 
with the -oroducer the retailer is not so greatly concerned. Con- 
signment goods selling, rilaces almost the entire financing of the 
merchandise ix-oon the manufacturers shoulders, why then the retailer? 
Manufacturers of tend bags have given in to this modern -oractice 
never graciously, however, and welcomed this clause and what is more 
used it. 

Section 11 -provided for cash discountr of 3/10 e.c.m. and anticipa- 
tion at the rate of 6' ; - ner annum. 

This nrovision was working very well at the close. Industry claimed 

it was a return to former terms used (see Exhibit G-, pp, 226 -oars. 
1 and 2, and cage 116 this history). Fought bitterly at the begin- 
ning it was accepted at the end. 

Section 13 forbade the acceptance of returned goods after a -period 
of not more than seven (?) days. 

Another growing evil treated on -page 67 this history. Accented much 
more readily at the close than beginning. A sound -provision and 
found to be generally workable. 

The second amendment to the code which unfortunately was not a-pr>rov- 
ed until a few days before the Supreme Court decision is treated on 
•page 69 this history. 

K. OTHFR PROVISIONS 

Compliance Records indicate an almost clean bill of health with res- 
pect to both Class A and 3 Trade Practice Provisions. It is to be 
ho-oed that a reader of this history will not conclude the industry 
were saints for they were far from that, A Directorate however, 
imbued, with a belief in the value of sound trade -oractice in general 
and their own Trade Practice -provisions in -particular, corrective 
in their attitude, was largely responsible for the -pretty clean 
charge sheets. All of the clauses contained had a value, some as 
•pointed out negative only, but even so, worth while. Other valuable 
provisions would have been added, in fact were well on their way to 
a-p-proval at the end, and these would have materially strengthened 
the industry's -position. 

1. Hedge Clause 

None such in this code. 

V. R^CO . 'ElOOATIOrS 

G-eneral Conclusions 

9811 



-97- 

Co'e writing should be approached much more circumspectly than it 
wp.g. Greater 'mo-'le'^e of vital statistics of ?n industry must "be 
had. The historic background of an industry must o" clearly laid 
down. 

Sponsors should he renuired to give this inf ormation. In addition 

they should state the practices followed and the evils the?' wish 

to correct, ouoting chapter and verse in suroort of positions taken. 

7or example: Had the Administration been given a geographical list 
of iaanufacturers and their approximate production together with a 

breakdown of employment in the f ! ctories, many of our difficulties 
in determinging wage and hour ouestions would have been eliminated 
and the representation nuestion settled almost out of h~nd. 

Terms and Discounts could, also have been settled auickly had we had 
real facts in the beginning. 

As it developed these ouestions "ere in the main settled reasonably 
and well, but one cannot but admit that conclusion? "ere based more 
upon a muddling through process rather than an orderly scientific 
one. 

Industry wants self governance, a sound idea, but only in so far as 
they aye prepared to accept an obligation should it be given, for 
implied in that are the preparatory stages and these should be taken 
before authority is given. 

Specific Recommend" tions 

The bringing together of labor and manufacturers on Code Authority 
Boards while theoretically sound in principle does not work out 
satisfactorily in practice. If all ""ere normal in their mental 
processes, or to put it another way, if they could forget past 
differences, perhaps it would have worked bette 1 -. Unfortunately 
this frame of minrl did not exist no it was too much to expect that 
it 'should, at le- st in a short space of time. The Manufacturers' 
general attitude seems to be that labor has some loathsome disease, 
while labor, and I'm now thinking only of this particular industry, 
acted in anything but a conciliatory manner, and as if they felt 
they were dealing with a lot of so and sos. G-ood reasons for this 
'possibly, much to be said in extenuation for such I am sure, but 
hone the less it does not make for calm deliberation and. order. 

In a case of this hind, if Cooes come back, I would strongly urge 
that labor representation come from, not the operating local, but 
one completely divorced from it. Such men could advise with the 
local on points brought out only germane to this industry, practice, 
etc. This will be objected to, if only on the score of cumbersome- 
ness, but I am certain in my own mind, that it would work, be found 
in the end much simpler, and the beginning of a better understanding, 
from which would soring good feeling between both. 

Most ill feeling springs from lack of knowledge and understanding. 
If a mental condition obtains, that makes for closed minds, we are 
not going to gain knowledge and understanding, hence friction and 
9G11 



-98- 

confusion worse confounded. 

By-Laws of Code Authorities should contain a. provision that code 
Directors should "be selected or elected by the Code Authority and 
that the right of hiring and firing rests in Directors. In this 
particular case no trouble in this respect developed, but in many 
industries the Code Director's work was badly hampered by the Code 
Authority's insistence upon controlling employment of the entire 
staff, and thus was developed what in effect was a.n industrial 
political machine, one resented by Industry. 

A. Undesirable or Unenforceable Provisions 

Some provisions in the Trade Practice division of this code are of 
course unenforceable and yet their ■ inclusion does have a moral ef- 
fect, therefore they should be included. All know the impossibility 
of imposing enforcement 100'' out no members of industry that I ever 
met, and there v, ere many, but agreed their effect was good. Of my 
own knowledge, this industry's Code Directors have, through all 
sorts of channels, more or less devious, kept close watch and were 
successful in checking, to an important degree, a straying from the 
straight and narrow path. Compliance records show but 4 complaints 
but I know of many that were checked without formal conrola.int being 
made, and of these we do not have record. 

3. Compliance 



As I have stated in previous chapters, due to the careful watchful- 
ness of the Code Authority staff, compliance standards were high. 
Attached as I was to a number of industries, my opportunities for 
comparison were great; and it can be ■ said that if this problem had 
been approached elsewhere as here, much of the friction developed 
would not have existed. See pages 50, 51, 59, to 61, 63, 96, to 98 
this history and Exhibits C, F, 3, ?.. for detailed particulars. 

C. Limitation on Production 

This was never attempted either in the Code or otherwise. 

D. Possible Code Consolidations 

The Luggage and Fancy Leather Goods, and Mens and "Tbmens Belts In- 
dustries should have been consolidated with Ladies Handbags. All 
follow in general the same factory practice, the same type of in- 
dividuals compose the different groups, and distributive channels 
used are the same. Trade Practice provisions would naturally need 
some adjustment. From such a grouping, strength would come to the 
Code Authority machine itself, and whnt is eoua.lly important, would 
enable the presentation of a united front to distributive groups, 
and thus more nuickly bring better practice. As set up today, each 
group, a separate entity, are relatively small and therefore, in 
their relations with the powerful well financed and entrenched buy- 
ers of their merchandise, are easily browbeaten into the following 
of bad practice. 

9811 



-99- 

Wage and Hour Provisions 

In the light of the Virginia Art Case referred to on pages 58, 95, 
96, this history and shown in Exhibit A. 1. One is tenvoted to say- 
wage provisions as set up were sound as applying to every part of 
the country. There was however, brought into that situation a 
factor that could not be used in all cases, the injection of a 
oualified expert on factory practice. Since such is not possible , 
and since we know "'e always have with us loose factory organization, 
I am inclined to believe a differential for markets located away 
from accented centres of a particular industry, of a particular 
industry, should be included in a new code. I think also that hour 
tolerances in the peak periods of the two selling seasons, is a need 
of all high style industries. Could this have been done, and an 
average struck for the year by lowering the number of hours allow- 
able in off seasons, industry and labor would come nearer an approach 
to peace. I know this is not the whole answer but it is definitely 
leading tx* ; way. 

May I conclude this history by expressing my own feeling about this 
industry. Utterly demoralized at the beginning of its code life it 
became united. Starting with nothing in the way of facts and figures 
it laid the foundation stones and built an appreciation of the value 
of such facts. Paced with many serious problems it tackled them in- 
telligently, as will be seen by a careful perusal of the Exhibits 
contained herein. Industry morale non-existent, came into being, 
and I feel that the industry, in making these first steps, has a 
right to be proud of itself, and the Administration in the great 
help it extended and gave has the right to be proud also. 



9811 



-100- 



PIK301UEL 



9811 



-101- 
PEHSOHKEL 



Division Administrators 

A. D. Whiteside 
Sol Rosenblatt 
George L. Berry 
Prentiss L. Coonley 
M. D. Vincent 

Deuvty Administrators 

Dr. Earl Dean Howard 
Dean Edwards 
Harry S. Berry 
Walter Mangurn 

Assistant Deputies 

Janes C. Worthy 
David. Barr 
Leigh E. Ore 

Ai de-.s 

Dana Hill 

Le : yal 

C-. II. Barenboim 
Hobart Newman 

C ons umers Advis ory Board 

Fred Huhlein 

Research & Planning Division 

Gretchen D. Cunningham 

Labor Advisory Boar vi 

Rose Schneiderrnan 
Pauline Gilbert 
Joseph Brodinsky 



Prom 



To 



August 1, 1933 March 15, 1934 
March 16, 1934 August 1, 1934 
August 1, 1934 August 28, 1934 
August 29, 1934 March 31, 1935 
April i, 1935 May 27, 1935 



August 1, 1933 June 16, 1934 
June 16, 1934 August 1, 1934 
August 1, 1934 January 28, 1935 
Jeuuary 29, 1S35 May 27, 1935 



July 3, 1933 August 1, 1934 
June 16, 1934 August 1, 1934 
August 1, 1934 January 23, 1955 



Jsnuary 29, 1935 May 27, 1935 



August 1, 1933 August 1, 1934 
August 1, 1934 May 27, 1955 



August 1, 1933 May 27, 1935 



August 1,1933 May 27, 1955 



December 8, 1933 June 30, 1935 
December 8, 1933 June 30, 1955 
July 1, 1934 May 27, 1935 \ 



;sn 



-102- 



Industrial Advisory Board 

Max Berkov/itz 
Mas Meyer 
E. L. Fries 
J. H. Davis 
Brag 7 Comer 
Houell Cheney 
£. G-. Son 

Administration Mem"bers 

0. W» Pearson 

(See: Reports Exhibit N) 

Dr, Paxil Ah el son 



From 

August 11, 1933 
April 11, 1934 
J-ane 28, 1934 
August 15, 1934 
October 27, 1934 
January 16, 1935 
February 1, 1935 



April 3, 1934 
May 10, 1934 
May 1, 1934 



To 

April 1, 1934 
June 28, 1934 
August 15, 1934 
October 27, 1934 
Jan„ 16, 1935 
Feb c 1, 1935 
May 27, 1935 



May 1, 1934 
May 27, 1935 
May 10, 1934 



9R11 



-103- 



EXHIBITS 



9311 



-104- 



EXHIBIT 



Letter of Trens littrl 
Excerpts from ori^i ri °l codes suoraitted 
& Rprts 



9811 



-105- 

EXHIBIT . A 
PART I 



CODL OF FAIR GOi PETITION 
for the 
LADIES HAHDBAG- INDUSTRY 

LLTTLR OF TRANSMITTAL 

National Recovery Administration 
Washington, D. C. 

The Associated Handbag Industries of America, Inc. submits herewith 
a Code of Fair Competition for approval by the President. This Code v;as 
adopted at a general meeting of the Association. 

The Associated Handbag Industries of Anerica, Inc. is an organiza- 
tion consisting of manufacturers and/or vholesale distributors of 
ladies handbags, pocketbooks and purses, representing by volume of 
business a^out seventy-nine per cent of the industry; the Association is 
national in scope and has a. membership of 100 concerns throughout the 
United States. This organization was incorporated June 14, 1932 under 
the laws of the State of Hew York; its objects are quoted herewith fro'm 
the -By-Laws: 

"The object of this Association shall be to secure and 
provide cooperation and united effort in all matter relating 
to the progress, development, welfare or improvement of con- 
cations in the Handbag Industry and Industries correlated and 
contributing to and affecting the welfare and progress of the 
Handbag Industry in all its branches; to foster the trade and 
commercial interests of its members; to secure freedom from 
unjust and unlawful enactions; to inculcate and maintain just 
and equ.itable principles; to eliminate iinfair or improper 
practices; to estaolirh and maintain uniformity and equity in 
the cu.stoms and commercial usagxs of the Industry; to acquire, 
preserve, collect and uisseminate business. .information, deemed 
useful, advantageous or valuable to its members regarding the 
Handbag Industry; to reform, correct and prevent any abuse and 
adjust commercial controversies, misunderstandings or grievances 
between members or between its members and the trade; to enforce 
its said objects and purposes among its members by such disciplinary 
and other measurers as may be agreed upon by them and as may be 
provided, by its By-Laws; and in general to do all matters tending 
to the improvement of the Handbag Industry in all its commercial 
asuects. " 



9811 



-106- 

The Associated Handbag Industries of America, Inc. affirms that 
it is trul-/ representative of the industry, and does not impose any in- 
equitable restrictions upon membership therein. 

The handbag industry being essentially a handicraft one, and 
subject to fluctuating jstyle tendencies, has been particularly affected 
by the economic depression of the last few years, and has been peculiarly 
subjected to unfair and uneconomic trade practices, such as price cutting, 
dumping of merchandise, rebates, etc. The Association in presenting 
this Code for approval, believes that it will restore the purchasing 
power of the employees of the industry and bring employment up to the 
1929 level, and restore the industry to its former healthy condition. 

For purposes of identification, the following statements are num- 
bered to correspond with the articles of the Code. 

Article 3. 

The employment of minors under the age of 16 has never been 
prevalent in the handba.g industry, but in order to make certain that 
this abu.se does not cre.ep in, the employment of minors under the age of 
16 is prohibited. 

Article 4. 

According to our bust information, approximately two-thirds of 
the industry is located, outside of Hew York, and the minimum wage paid 
is $7.00 per week. The establishment of a minimum wage of Z0<£ per hour 
outside of Hew York represents ani increa.se of approximately 42$ and in 
order to compensate for the difference in living costs in Hew York City, 
a differential of 20$ is provided for. 

Article 5. 



The menber of hours worked per week in the industry ranges 
from 44 to 54, and in one or two instances higher. The average number 
of hours worked per week is approximately 48. The reduction in working 
hours to a minimum of 40 or an average reduction of 2(5$, will provide 
for an increase in employment sufficient to provide for the unemployed 
workers in the industry. 

Article 6 . 

In order to identify all pocketbooks and handbags as having 
been manufactured under the conditions approved by this code, it is 
provided that all handbags and pocketbooks shall bear an NRA label. 
The publicity given to all products with an NRA lable will tend to 
increase the sale of such products, which in turn will make it possible 
for the industry, to pay the wp^ges as contemplated under this Code, and 
to take up the unemployed in the industry. 



9811 



-107- 

Article 7. 

In order to make effective the provisions of this Code, an 
administrative body to be known as the Handbag Code Authority is set up. 
This Handbag Code Authority, which shall be truly representative of the 
industry, will be empowered to make previsions for the enforcement of 
this Code, and to make such recommendations to the Administrator as may 
be necessary from time to time. It is contemplated that conditions may 
arise which will tone to obstruct the smooth operation of the Code, and 
it will be the duty of the Handbag Code Authority to investigate and 
recommend the necessary remedial measures. To that end, full reports and 
data are to be furnished by members of the industry. 

Article 8 » 

The National Industrial Recovery Act does. not require manufacturers 
in any industry to hold membership in the Association, but the Code 
being administered for the benefit of the industry, it is only .just 
and proper, that every person in the industry pay his proportional share 
of the maintenance of the machinery necessary to effectuate the provi- 
sions of this Code. 

Articles 9 and 10 . 

A true knowledge of costs is absolutely essential to the welfare 
of any industry. Price-cutting and excessive values arc very frequently 
due to a lack of true knowledge of costs. 

To insure the industry against unfair competition resulting from 
lack of complete knowledge of costs and in many instances from no 
knowledge of costs at all, the Association will furnish uniform cost 
sheets to every manufacturer in the industry. These cost sheets will 
be approved by a committee of the Association and will be based on the 
cost system now in use by the various manufacturers in the industry. 

Article 11. 

For years the industry maintained its cash discount on a basis 
of 2/10/60" and then changed to 3$ EOM.' Daring the past four years, 
through unfair practices and greed on the part of tie manufacturers, 
cash discounts have risen to 8'.. and in some cases as high as 10$, and 
this in view of possibly only 1-gjS earned in discount by the manufacturer, 
on the basis of his sales. 

■ This wide difference between the discount earned by the manu- 
facturer and the discount he is compelled to give, is unwarranted and 
uncalled for, and it is a. source of great loss to the industry and must 
be corrected. 

Unless cash discounts are absolutely uniform throughout the in- 
dustry, the temptation to use various discounts within limits set is 
a form of rebate. 



9811 



-108- 

Article 12. 

This article is designee?, to prevent the establishment of sub- 
standard shops in the industry hy large consigners of the industry' s 
products. The establishment of such si ops, which are temporary in 
nature, does more harm to the legitimate employers in the industry 
than any other single factor. Bus to their temporary character, 
effective control is almost impossible, and in order to do away with 
this evil, this article prohibits such practices. 

Article 13. 



One of the greatest losses in the industry has resulted from 
over-production, with the sacrificing of goods at the best prices 
obtainable in, an inactive market, and the consequent lowering of stand" 
ards of values. t is contemplated that the Handbag Code Authority 
will maintain a close supervision to prevent over-production, with its 
attendant losses to tin industry. 

Arti cle 14 . 

The Handbag Industry is particularly one of style and season. 
The ingenuity and creative ability of any person should be protected 
for sufficient time so that the oryinator may reap the full benefits 
of his creative ability. 

The wasteful practices now prevalent in the industry which result 
in severe losses through mark downs to manufacturers .and retailers, 
due to unwarranted and para-icic copying and imitating or distinctive 
styles originated by manufacturer? ir: the industry, must be eliminated. 
This pra.cticc constitutes unfair competition and it is against the 
interests of all the manufacturers in the industry. 

In order to carry out the plan, the Handbag ©ode Authority will 
establish and maintain a. REGISTRATION BUREAU. Any person may register 
with the Bureau any original a- si a, a i .rial or process. The Bureau of 
Registration '.Till also be available to any person, trade or industry 
selling to th„ ladies handbag industry, who wishes to register with the 
Bureau any frame, my original design on leather or material, or original 
process. 

A rticle 15. 

The trade practice rules under this article, such as rebates, 
consignment selling, unjustified returns, breach of contracts, defama- 
tion of competitors, and false or exaggerated advertising, were adopted 
by the Association a year ago, and arc substantially identical with 
provisions approved by the Federal Trade Commission for similar in- 
dustries. 

The remaining sections of the 6ode are mandatory provisions 
of the Act, and do not require any discussion. 



9811 



-109- 

It is the purpose of the Association by this Code to regulate 
and correct these abuses. The Association is both ready and able to 
assume the task of and the responsibility for, the rehabilitation of 
the handbag industry. With that end in view, the Association states 
that the Code of Fair dompetition herewith presented, will not tund to 
promote monopolies nor oppress or discriminate against small business 
enterprises, and that it v/ill be fair to competitors, employees and 
consumers, alike. 

Respectfully submitted, 

ASSOCIATED HANDBAG INDUSTRIES OF AMERICA, INC. 
August 28, 1933 

(Signed) Maurice S. Mosesson, 

Executive Secretary 
MSl.i:AS ' • 



9811 



-110- 
3XKIBIT A 

n?-- 2- . 

C£)TE OI'.ZJAIP COLiES'TITION 
for the 
LADIES IZAiTGLAG IFjUSTEY 



To effectuate the policy of Title I of the "Tational Industrial 
P.ecover/- Act, this Code is set itfp... for the purpose of increasing em- 
ployment, establishing fair and adequate wages, effecting necessary 
reduction of hours, improving standards of labor, and eliminating un- 
fair trade practices (etc.); to maintain a reasonable balance between 
production and consumption, and to restore the income of enterprises 
within the industry to levels which will make possible the payment of 
such wages and avoid the further depletion and destruction of capital 
assets, to the end of rehabilitating the handbag industry and enabling 
it to do its part toward establishing that balance of industries which 
is necessary to the restoration and maintenance of the highest practi- 
cal degree of public welfare. 

I - DErihlTIOITS 

The term "handbag industry" as used herein is defined to mean the 
manufacture and/ or wholesale distribution of ladies' handbags, pocket- 
hooks and purses. The term "person" as used herein shall include nat- 
ural persons, partnerships, associations anc corporations. The term 
"employer" as used herein shall include every person actively engaged 
in the production and/or wholesale distribution of products of the hand- 
bag industry as herein defined. The term ''effective date" as used herein 
is defined to mean the second Monday after this Code shall have teen ap- 
proved by the president of the United St: es, 

II - As required by Section 7 (a) of Title I of the national Industrial 
Recovery Act, the following provisions are conditions of this Code: 

"(1) That employees shall have the right to organize and 
bargain collectively through representatives of their own 
choosing and shall he free from the interference, restraint, 
or coercion of employers of labor, or their agents, in the 
designation of such representatives or in self -organization 
or in other concerted activities for the purpose of collec- 
tive bargaining or other mutual aid or protection; 

(2) That no employee and no one seeking employment shall be 
required as a condition of employment to join any company 
union or to refrain from joining, organizing or assisting a 
labor organization of his own choosing; and 



9811 



-Ill- 



(3) That employers shall comply with the maximum hours 
of labor, minimum rates of pay, and other conditions of 
employment approved or prescribed by the President." 

III - On and after the effective date, employers shall not employ 
any minor under the age of sixteen (16) -ears. 

IV - On and after the effective date, the minimum wage that shall 
be paid by any employer to any of their employees, except learners 
during a three months apprenticeship, shall be at the rate of: 

(1) 25f! per hour when employed outside of Greater New "fork 
and immediate vicinity, 

(2) 30^ per hour when employed within Greater New York 
and immediate vicinity. 

V - On and after the effective date, employers shall not operate 
on a schedule of hours of labor for their employees in excess of 
forty hours per week, except inj office and supervisory staff, ship- 
ping and sales force. 

VI - LI CENSES 

(1) Reeognizing that the stability of the industry and 
the ability to carry into effect the purpose and intent 

of this act depends entirely upon the complete cooperation 
of all those engaged in the handbag industry and with a 
view to effectuating such complete stabilization, all per- 
sons, members of the association set forth in this code, 
shall by virtue of their membership be deemed collectively 
to have been licensed to <?o business in this industr- under 
this act. 

(2) All persons engaged in the handbag industry and not 
a member of the association named herein shall, promptly 
following the effective date of this code, obtain and pro- 
cure from the Administrator, subject to the approval of 
the committee, a license or permit thus to engage or con- 
tinue in business, which shall be conditioned upon the 
obligation of such applying firm to comply with all and 
every provision of this code and the amendments thereof, 
and such other and further regulations as may be prescribed 
by the committee together with the Administrator. 

VH-a. ADMINISTRATION 

The Associated Handbag Industries of America, Inc. is hereby 
designated the agency for administering, supervising and promoting 
the performance of the provisions of this code by all employers in 
the handbag industry. 



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To effectuate the provisions of this Code, the Board of Gov- 
ernors as the governing "body of the Associated Handbag Industries 
of America, Inc., is hereby authorized to appoint such agents or 
agencies, as it finds necessary, and to clothe these agents or agen- 
cies with the powers necessary to carry out the authorit?/ vested in 
the Board. This agency or agencies to have plenary powers and sole 
discretion, ana to be assisted by an A 1 visory Council, consisting of 
chosen representatives of every branch of the industry, which will 
act under the sole authority of this agent, 

(b) The Advisory Council is hereby designated as a planning, 
fair practice and control ling agency for the industry. This agency 
may from time to time present to the Administrator of the industry 
recommendations based unon conditions in the 'industry, as they may 
develop from time to time, which will tend to effectuate the operation 
of the provisions of the Code anc the policy of the Rational Industrial 
Recovery Act, and in particular along the following lines: 

(c) Recommendations for the making of rules by the Administrator 
as to -ractices by persons eny-ye'. in the handbag industry as to methods 
and conditions of tracing, the nami . and ia porting of prices which may 
be appropriate to avoi> discrimination to promote the stabilization of 
the industry, to prevent and eliminate unfair and destructive competi- 
tive prices and practices. 

(d) Recommendations for the setting up of a Service Fureau for 
engineering, accormtin v, credit or any other purposes that may aid 
the conditions of this emergency and the requirements of this Code. 

(e) Recommendations fcr the requirement by the Administrator 

of licensing and registration of persons engaged in the handbag indus- 
try not members of the association named herein to be made effective 
as speedily as ca.n conveniently be aon^ to the end that the provisions 
of this Code ma - / become immediately operative. 

(f) Recommendations for regulating the disposal of distress 
merchandise in the following way, becau.se that will secure the pro- 
tection of the owners thereof and at the same time promote the sound 
and stable conditions in the inaustry. Distress merchandise may be 
disposed of in the following manner and during the following periods 
only; general fall competitive items after Curistmas, general spring 
competitive items after hay 15th, and general summer ocmroetitive items 
after July 4th, Tvery person is required to notify the Advisory Council 
immediately after disposing of distress merchandise, jobs or under- 
priced merchandise during the periods as above stated, giving the 
following information: 

ilame of purchaser 
Date of purcxia.se 
Quantity sold 
Regular arice 
Price at which sold 
Reasons for selling 

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(g) Recommendations for dealing with any inea inlities that 
may otherwise, arise that may endanger the stability of the industry 
and/or oroduction and employment. 

(h) Such recommendations, when approved "by the administrator, 
shall have the same force and effect as any other provisions of this 
Code. Such agency shall likewise coooerate with the Administrator in 
making any and all investigations as to the changing and observance 
of any of the provisions of this Code at its own instance or upon com- 
plaint of any one of the members of the foregoing Committee. The said 
agency shall investigate the matter or matters complained of and re- 
port its findings and recommendations to the Administrator for appro- 
priate disposition. 

VIII - CODE REPORTS AND FEES 

In order that the President may be informed of the extent of 
observance of the provisions of this Code, and of the extent to which 
the declared policy of the National Industrial Recovery Act as stated 
herein is being effectuated in the handbag industry, persons subject 
to the jurisdiction of this Code shall at its request make neriodically 
to the Advisory Council such reports on wages, hours of labor, condi- 
tions of employment, number of emnlovees, production, shipments, sales, 
stocks, -prices and other data pertinent to the purposes of this Code 
as may be reauired; shall permit inspection of pertinent records by 
authorized agents, and shall pay as a code fee his proportionate share 
of the amounts necessary to pay the cost of assembling, analysis and 
publication of such reports and data, and of the maintenance of said 
Association and its authorized agents and activities in assisting the 
National Recovery Administration in effectuating in the handbag indus- 
try the purposes and requirements of the National Industrial Recovery 
Act as stated herein. 

' Except as otherwise provided in the National Industrial Recovery 
Act, all statistical data filed in accordance with the provisions of 
this Article shall be confidential. 

IX - Each employer must use, keep and maintain uniform cost sheets 
as may be adopted by the Advisory Council. 

Every article sold by the employer must be figured on these 
cost sheets, which shall be kept in a loose-leaf binder furnished 
by the Association, and open to inspection in accordance with Article 
VIII. Every employer shall swear that these cost sheets represent 
every article manufactured by him, and that they are the true and only 
cost sheets kept by him. 

X - It shall be considered an unfair method of competition to sell 
products of the industry below cost excepting distress merchandise as 
allowed under this code and provided for. The Advisory Council shall 
formulate the method of determining cost and shall take into considera- 
tion the following factors: cost of labor, materials and over-head. 



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XI - It shall "be considered an unfair method of comoetition to shin 
handbags a.t wholesale, at terms other than 3/1" 1 e.o.m. ; anticipation 
to be allowed at the rate of six (6) per cent per annum. 

XII - CONTRACTING 

The furnishing of leather, frames, or other materials to con- 
tractors by a retailer or retailors, a chain store organization, a. 
resident buying office or a mail-order house for the purpose of hav- 
ing these materials made into a finished product for the use of the 
said retailer, chain store cr<?vuii nation, resident buving office or 
mail-order house, is cj";3idered ax unfair irade practice. 

The contractor is hereby defined a,s a person employing labor in 
the manufacture of the products of the industry, who does not make a 
practice of buying his own ar.Rieri6.Ia ov to whom materials are consigned 
for the purpose of making them into a finished product for the consignor. 

XIII - To effect the declared ourpo>ss of this Code in respect to 
maintaining a reasonable balance between the production and consumption 
of ladies handbags, the industry , go 33 on record as in favor of a control 
of production, The method of the control of production and the effec- 
tive date shall be determined by the Board of C ov ernors. 

XIV - REGISTRATION 

In order to orotect originalitv of design, materials or processes, 
a Registration B ireau is hereby estallished. 

Any original article, design, material or process may be regis- 
tered by any oerson in the indus + rv or by any person who sells his 
product to the industry, and when so dal Tr registered with the Registra- 
tion Bureau, it snail be protected agsii?.sb copying for a period of three 
(3) months from the date of registral ion, and ail pers-xs are orohibited 
from coovinr sucn registered article, design, material or orocess, or to 
purchase a cooy or imitation of such registered article, design, material 
or orocess for a \eriod of three (3) months from the date of registration 
thereof, 

XV - TRADE PRACTICES 

(a) The making of any secret pavments or the making of any al- 
lowance of rebrtes, refunds, commissions, or unearned aiscounts, whether 
in the form of money or otherwise, or the secret extension to certain 
purchasers of special services or oriviieges not extended to all pniy- 
chasers, under like terms and conditions, with the intent and withft.he 
effect of injuring a competitor and where the effect may be to substan- 
tially lessen competition or tend to create a mononolv or to unreason-^ 
ably restrain trade, is an unfair method of competition. ^ 



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("b) The giving, selling,' delivering or shining to anvone, 
products of the handbag industry either directly or indirectly, or 
by any other wavs or means whatsoever, on an arrangement or under- 
standing known as "memorandum", or "consignment" or "on approval" for 
any length of time whatever, with the ri^ht or privilege to the cus- 
tomer or consignee of selling or offering same for sale, and with the 
further privilege to the said customer or consignee of returning all 
or any part of such merchandise so shipped or delivered, or with the 
further orivilege of exchanging all or any part of such merchandise, 
is an unfair method of competition. 

(c) The indirect Or direct giving or permitting to be given or 
offering to give money or anything of value to agents, employees, or 
representatives of customers or prospective customers, or to agents, 
employees or representatives of competitors customers or prospective 
customers, with or without the knowledge of their employers or prin- 
cipals, as an inducement to influence their employers or principals 

to purchase or contract to purchase industry products from the maker of 
such gift or offer or to influence such employers or principals to re- 
frain from dealing or contracting to deal with competitors, is an unfair 
method of competition. 

( d) The paying for retailers newspaper advertising, whether in 
the form of money or otherwise, constitutes a form of rebate and is 
therefore' an -.unfair method of competition. 

(e) The accepting of a return of any merchandise shipped to a 
purchaser and' the giving to the purchaser credit therefor, or the ex- 
changing of merchandise for the purchaser, where the merchandise has 
been shipped in accordance with all the specifications of the order and 
within the specified time or where the purchaser has ordered merchan- 
dise in excess of his need with the intent to return part, or where 
the merchandise has been in the possession, actual or constructive, of 
the purchaser for more than five davs, is an unfair method of competi- 
tion. 

(f) The malicious inducing or attempting to induce the breach 
of existing contracts between competitors and their customers by any 
false or deceptive means whatsoever, or the interfering with or obstruct- 
ing the performance of any such contractual duties or services by any 
s>Lch means, with the purpose and effect of unduly hampering, injuring, 

or embarrassing competitors in their businesses, is an unfair method of 
competition. 

(g) The defamation of competitors by falselv imputing to them 
dishonorable conduct, inability to perform contracts, questionable credit 
standing, or by other false representations, or false disparagement of 
the grade or quality of their goods with the tendency and capacity to 
mislead or deceive purchasers or prospective purchasers, is an unfair 
method of competition. 



9811 



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(h) The making of any false or exaggerated statement "by any 
oerson in his advertising or the making of false or unfair compari- 
sons with the Droducts of other manufacturers, is an unfair method 
of competition. 

XVI - The administrator is expressly authorized to deputize the Ad- 
visory Council named herein and/or its representatives to do and per- 
form such acts as may be necessary to carry into effect the purpose 
and intent of this code. 

XVII - This trade association affirms' tha.t it imposes no ineauitable 
restrictions on admission to membership therein, and is truly repre- 
sentative of the handbag industry- 

This Code is not designed to promote monopolies, and shall not 
be availed cf for that purpose. 

The provisions of this Code shall not be so interpreted or ad- 
ministered as to eliminate or oppress small enterprises, or to dis- 
criminate against them. 

This Code and all the provisions thereof are expressly made 
subject to the right of the President, in accordance with the provi- 
sion of Cla'.ase 10 (b) of the National Industrial Recovery Act, from 
time to time to cancel o^ modify any order, approval, license, rule, 
or regulation, issued under ^itle I of said fe.c$, and specifically to 
the right of the President to cancel or moiify his approval of this 
Code or any conditions i.nposed by him upon his approval thereof. 

Suoh of the provisions of this Code as are not required to be 
included therein by the National Industrial Recovery Act, may with the 
approval cf the President, be modified or eliminated as changes in cir- 
cumstances or experience may indicate. 1 ■ is contemplated that from 
time to time supplementary provisions to this Code or additional codes 
will be submitted for the approval • of the President to prevent unfair 
competitive practices and to effectuate • the other purposes and policies 
of Title I of the National Industrial Recovery Act consistent with the 
provisions hereof. 

XVIII - If any employer of labor in the handbag industry is also an 
employer of labor in any other industry, the provisions of this Code 
shall apply to and affect only that part of his business which is in- 
cluded in the handbag industry. 

XIX - VIOLATIONS 

Violations by any persons subject' to the publications of this Code 
of any provisions of this Code, or of any approved rule issued thereunder, 
or of any agreement entered into by him with the Advisory Council to ob- 
serve and conform to this Code and said rules, is an unfair method of 
competition, and the offender shall be subject' to the penalties imposed 
by the National Industrial Recovery Act. 



9811 



-117- 

EXHIBIT A 
P1T.T 3 
AS REVISED AUGUST 13, 1933 AND ONLY CONTAINING CHANGED PORTIONS 

ARTICLE I - DEFINITIONS 
*** 

ARTICLE II - STATUTORY LABOR PROVISIONS 



ARTICLE III - CHILD LABOR 



ARTICLE IV - "AGES 

On and after the effective date the minimum wage that shall be 
paid "by any employer to any of his employees shall be at the rate of: 

(1) 30^.. per hour when employed outside of Greater New York and 
immediate vicinity. 

(2) 35ji, per hour when employed within Greater New York and 
immediate vicinity. 

Provided, however, that learners, for a period of not more than 
three months, shall not "be paid less than 80$ of the above minimum rates. 
A learner is hereby defined as a factory worker, who has never worked in 
the industry. 

The total numbers of learners in any factory shall at no time exceed 
15fo of the total number of factory employees. 

ARTICLE V - HOURS 
*** 

ARTICLE VI ~ LABELS 

ARTICLE VII - HANDBAG CODE AUTHORITY 

(a) The responsibility, for the administration and enforcement of this 
Code shall be vested in a Handbag Code Authority. This Handbag Code 
Authority shall be selected by the Beard of Governors of the Associated 
Handbag Industries of America, Inc., and shall be truly representative 
of the industry. 



9811 



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(b) The Handbag Code Authority is hereby designated as a planning, 
fair practice and controlling agency for the industry. This agency may 
from time to tine present to the administrator of the industry recommen- 
dations based upon conditions in the industry, as they may develop 

from time to time, which will tend to effectuate the operation of the 
provisions of the Code and the policy of the national Industrial Re- 
covery Act, and in particular along the following lines: 

(c) Recommendations as to the rergiircment by the administrator 
of such other and farther reports from persons engaged in the handbag 
industry of statistical information and the keeping of uniform accounts 
as may be required to secure the proper observances of the Code and pro- 
mote the proper balancing of prrdvetion. distribution and consumption 
and the stabilization of the industry and employment. 

(d) Recommendations for the setting up of a service bureau for 
engineering, accounting, credit or any other purposes that may aid in 
the conditions of this emergency and the requirements of this Code. 

(e) Recommendations for the making of rules by the administrator 
as to practices by persons engaged in the handbag industry as to methods 
and conditions of trading, the naming and reporting of prices which may 
be appropriate to avoid discrimination, to promote the stabilization of 
the industry, to prevent and eliminate unfair and destructive prices and 
practices. 

(f) Recommendations for regulating the disposal of distress mer- 
chandise in the following way, because that will secure the protection 
of the owners thereof and at the same time promote the sound and stable 
conditions in the industry. Distress merchandise may be disposed of in 
the. following manner, and during the following periods only: general 
fall competitive items after Christmas, general spring competitive 
items after May 15th, and general summer competitive items after July 
4th. Every person is required to notify the Handbag Code Authority 
immediately s.fter disposing of distress merchandise, jobs or undcr- 
prices merchandise during the periods 2.3 above stated, giving the follow- 
ing information; name of purchaser, date of purcha.se, quantity sold, 
regular price, price at which sold and reasons for selling. 

(g) Recommendations for dealing with any inequalities that may 
otherwise arise that may endanger the stability of the industry and/or 
production and employment. 

Such recommendations, when approved by the administrator shall 
have the same force and effect as any other provisions of this Code. 

The Handbag Code Authority shall have power to examine all books 
of accounts and records of employers to ascertain whether they are 
observing the provisions of this code, and all employers shall submit 
their books and records for such examination. 

The Handbag Code Authority shall have power to appoint a director, 
a staff of accountants and such other employees as may be required for 
the effective discharge of its functions. 



9811 



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The e;cpense of maintaining the handbag Code Authority shall he borne 
by the Associated Handbag Industries of America, Inc., the parties to this 
Code, and all other employer s in the industry in such proportions and 
amounts and in such manner as may be determined by the Handbag Code Authority, 

ARTICLE VIII - CODE REPORTS AND FEES 



*** 



#*# 



**# 



*** 



*** 



*** 



*** 



*** 



*** 



*** 



ARTICLE IX - COST RECORDS 



ARTICLE X - SELLIIIC- BELOW COST 



ARTICLE XI - TEEMS 



ARTICLE XII - CONTRACTING 



ARTICLE XIII - CONTROL OF PRODUCTION 



ARTICLE XIV - REGISTRATION BUREAU 



ARTICLE XV - TRADE PRACTICES 



ARTICLE XVI - ADMINISTRATION 



ARTICLE XVII - STATUTORY PROVISIONS 



ARTICLE XVIII - APPLICATION OP CODE 



ARTICLE XIX - VIOLATIONS 



9811 



-120- 

EXHIBIT A 

PART 4 



Draft of 
ITovember 6, 1933 



PROPOSE) COTE 
OP 
PAIR COIPETITIOIT 

POT: THE 
LADITS' HAliTBAG IhDUSTRY 



ARTICLE I 

Purposes 

To effectunte the policies of Title I of the National Industrial 
Recovery Act, the following rovisions are submitted as a Code of Pair 
Competition for the Ladies' Handb.' : Industry, and upon approval hy the 
President shall he the standard of fair cor, petition for this industry 
and shall he binding upon every member thereof. 

ARTICLE II 

Definitions 

1. The tern " Industry" r~ used herein includes the manufacture of 
ladies' handbags, pr chetboolcs and n.rses. 

2. The tern "ermloyee" as used herein includes any person engaged 
in any phase of the industry, in any cnr.city, receiving compensation 
for his services, irrespective of the nature or method of -oayment of 
such compensation. 

3. The tern "employer" as used herein includes anyone for whose 
benefit or -.hose business such an exmloyee is engaged. 

4. The tern "rienber of the industry" includes anyone engaged in 
the industry, either as o.n endoyer or on his or:n behalf. 

5. The term "President", "Act", and "Administrator" as used 
herein shall mean respectively the President of the United States, 
the national Industrial Recovery Act, and the Administrator of Title 
I of said ^.ct. 



9811 



-121- 

ARTICLE III 
Hours 

1. Except as hereinafter provided, no employee shall be permitted 
to work in excess of forty (40) hours in any one week, nor in excess 

of eight (8) hours in any twenty-four (24) hour period. 

2. Ho person employed in shipping, clerical or office work, unless 
he is employed in a managerial or executive capacity and earns not less 
than thirty-five ($35.00) per week, shall be permitted to work in excess 
of forty (40) hours in any one week nor in excess of eight (3) hours in 
any twenty-four (24) hour period. 

3. The provisions of this Article shall not apply to outside 
salesmen. 

4. Subject to review by the Administrator f the Code Authority 
shall designate the hour before which work shall not begin and the hour 
after which work shall not continue. In the discretion of the Code Auth- 
ority such opening and closing hours need not be uniform throughout the 
country but may be varied to meet varying needs rnd conditions. 

5. ITo manufacturing operations shall take place on any Saturday 
or any Sunday. 

6. No member of the industry shall engage any employee for any time 
which when totaled with that already performed with other member or mem- 
bers of -. tho industry exceeds the maximum permitted herein. 

ARTICLE IV 

ITages 

1. Except as hereinafter provided no employee shall be paid at 
less than the rate of thirty cents (30rf) per hour when employed within 
Greater Hew York ~nd the immediate vicinity thereof, nor less than 
twenty-five cents (25^) per hour when employed outside Greater New York 
and the immediate vicinity thereof. 

2. Persons learning an occupation shall be paid not less than 
eighty per cent (80$) of the mini^mm wage which prevails in such occu- 
pation, and the number of such workers shall not exceed five per cent 
(5$) of the number of employees of any one employer and no person shall 
be employed as a learner for a period in excess of three (3; months ir- 
respective of whether they are employed by one or more employers. 

3. This Article establishes a. minimum rate of -pry which shall apply 
irrespective of whether an employee is compensated on a piece rate,' time 
rate or other basis. 

4. The wage rates for occupations other than those receiving the 
minimum wage herein prescribed shall at least maintain the difference 
in earning for those occupations for a full-tine week existing on 

9811 • • • . ' 



-122- 

October 1, 1933 provided, however, that these rr.tes sho.ll he subject to 
reconsideration for adjustment by the Code Authority and by the Admin- 
istrator. 

5. Subject to review "by the Code Authority and by the Adminis- 
trator;, no employer shall reduce the weekly compensation for employ- 
ment now in excess of the minimum virtus established herein, notwit.hsto.nd- 
ing that the hours worked in such employment may hereby be reduced. 

ARTICLE V 

General Labor Provisions 

1. Ho person under sixteen (16) years of age shall be employed in 
the industry. 

2. Employees shall have the right to organise and bargain collec- 
tively, through representatives of -heir own choosing, and shall be free 
from the interference, restraint, or coercion of employers of labor, or 
their agents, in the designation of such representatives or in self-or- 
ganization or in other concerted activities for the -raroose of collec- 
tive bargaining or other mutual aid or protection* 

t 

3. lib employee and no one ssehing employment shall be required as 
a condition of employment to join any company union or to refrain from 
joining, organizing., or assisting r labor organization of his ovm choos- 
ing. 

4. Employers shall comply with the maximum hours of labor, minimum 
rates of ;:>ay, end other conditions of emoloynent aworoved or prescribed 
by the President. 

5. No employer shall reclassify employees or duties or occupations 
performed for the ^uroose of defeating the provisions of the Act or of 
the Code. 

6. Every employer shall 'orovide for the safety and health of his 
employees. Standards for safety and hqalth shall be submitted by the 
Code Authority to the Administrator within six (6) mouths after the ef- 
fective date of this Code. 

7. Y\o provision in this Code shall supersede any law within any 
State which in; y oses more stringent requirements on employers as to age 
of employees, wages, hours of work, or as to safety, health, or sanitary 
regulations, or insurance, or fire protection, or general working con- 
ditions, than are imposed by this Code. 

8. Nothing herein contained shall apply to emoloyees where terms 
of employment are established by labor agreements, understandings, and 
practices now in force, where the wage and hour provisions so established 
are more favorable to emoloyees than those set forth in this Code.„ 

9. All employers sho.ll post complete copies of Articles III, IV, 
and V of this Code in conspicuous plaoes accessible to employees. 

9811 



-123- 

10, Ho provision of this Code shall modify established practices 
or privileges as to vacation periods, leaves of absences, or temporary 
absences fron work heretofore granted to office employees. 

11, No member of the industry shall give out work to be performed 
in any home or dwelling place. 

12. Any -oerson who shall at any time manufacture any article or 
articles subject to the provisions of this Code shall be bound by all 
the provisions of this Code as to all emalo^ees e?agaged, in whole or in 
part, in such manufacture. In case any ennloyee shall be engaged partly 
in such manufacture and partly in the manufacture of goods of another 
character, this Code shall apply to such portion of such employee's time 
as is applied to the manufacture of articles subject to the provisions 
of this Code. 

13. Ho member of the industry shall give out ',7ork on a. contract 
basis unless such work is given out with a. written agreement that the 
contractor and all other prrties to such contract shall cornly with all 
the pertinent nrovisions of this Code. The Code Authority shall draw 
up a uniform agreement which shall be used whereever and whenever work 
is given out on a. contract basis. 

ARTICLE VI 

Administration 

1. A Code Authority is hereby constituted to cooperate with the 
Administrator in the administration of this code. 

2. The Code Authority shall consist of members to be sel- 
ected in the manner hereinafter set forth: 

(a) nembers shall be appointed "oy the Board of Gover- 
nors for the Associated Handbag Industries of America, Inc. 

(b) members shall be aroointed by the Uidwestern 

Handbag Association. 

(c) members shall be appointed ^oj the Popular Priced 

Handbag Association. 

(d) One (l) member shall be aroointed by the Adninistrrt or on 
the nomination of the Labor Advisory Board ,of the national Recovery Ad- 
ministration. 

(e) One (l) member shall be appointed by the Ad sinistra tor on 
the nomination of the Consumers' Advisory Board of the national Recovery 
Administration. 

(f) One member shall be ap >ointed by the Administrator to repre- 
sent the Administrator. 



9811 



-124- 



3. Each trade or industrial association directly or indirectly 
participating in the selection or activities of the Code Authority , 
shall (l) imoose no inequitable restrictions on membership, and (2) 
submit to the Administrator brae o"-ncs of its articles of associ- 
ation, Ly-lr^s- i 'epilations, and any amendments when node thereto, . 
together with such other information as to membership, organization, 
and activities as the Administrator nay deem necessary to effectu- 
ate the -pun oses of the Act. 

4. In order that the Cede Authority shall at all tines he truly 
representative of the industry end in other res'oects comply with the 
provisions of the Act. the Administrator F*ay provide such hearings as 
he nay deem proper, and :ia" require an appropriate modification in 
the method of selection of the Cole Authority. 

5. Nothing contained in this Code shall constitute the members 
of the Code Authority partners for any 'ruroose. Ilor shall any member 
of the Code Authority he liable in en./ manner to anyone for any act 
or any other me iber, officer, agent or em loyee of the Code Author- 
ity. Ilor shall any member o-f the Code Authority be liable to my one 
for any action or omission to act under the Code, except for his will- 
ful misfeasance or non-fe; sance. 

6. The Code Authority shell, have the following powers and duties, 
to uio extent permitted by the Act, end subject to the right of the 
Administrator, on review, to disap rove or modify any action taken by 
the Code Authority, 

(a) To adoot a constitution, by-laws and rules and regu- 
lations for its procedure and for the administration and enforcement 
of this Code, raid to submit the sane to the Administrator for his ap- 
proval together with true copies of rny amendments or additions when 
made thereto, minutes or meeting:, when held, and such other informa- 
tion as to its activities rs the Administrator may deem necessary to 
effectuate the yurnoses of the Act. 

(b) To obtain through a confidential agency from the members 
of the industry reports based or: periods of two, or four weeks, or multi- 
ples thereof, for use of the Code Authority and the Administrator in the 
administration and enforcement of bhis Code, rnd for the information of 
the President, and to give assistance to member-: of the industry in im- 
proving methods, and otherwise. 

(c) To receive complaints of violations of this Code, nake 
investigations thereof, provide hearings thereon and adjust such con- 
plaints, end bring to the attention of the proper authorities for pro- 
secution recommendations and information relative to unadjusted viola- 
1 at ions. 

(d) To use such trade associations and other agencies as it 
deems proper for the carrying out of air" of its activities provided for 
herein and to pay such trade associations and agencies the cost thereof, 



9811 



-125- 

provided that nothing herein shall relieve the Code Authority of its 
duties or responsibilities under this Code and that such trade asso- 
ciation and agencies shall at all tines he subject to and comply with 
the orovisions hereof. 

(e) To coordinate the administration of this Code with such 
other codes, if rny, as may he related to this industry, or any sub- 
divisions thereof, and to delegate to any other administrative auth- 
ority, with the approval of the Administrator, such powers as will 
-nromote joint and harmonious action upon matters of common interest. 

(f ) To secure an equitable and proportionate payment of 
the expenses of the maintaining the Code Authority and its nativities 
from those members of the industry accenting the "benefits of the acti- 
vities of the Code Authority or otherwise assenting to this Code. 

(g) To provide for an IIRA Code insignia for the exclusive 
use of the members of the industry and to establish appropriate mach- 
inery for the issuance of such insignia. All articles subject to the 
provisions of this Code shall bear such an insignia and each member of 
the industry shall be entitled to the use of such insignia provided that 
they agree to and comply with the provisions of this Code, The Code 
Authority shall have the sole right to distirbute and sell such IIEA 
Code insignia in this industry. 

ih) To establish or designate an agency on planning and fair 
practice which shall cooperate with the Code Authority in developing 
fair trade practices and industrial planning, including the regulari- 
zation and establlization of employment for tho industry. 

(i) To initiate, consider, and make recommendations for 
the modification or amendment of this Code. 

(j) To create as an agency of the Code Authority a JOINT 
INDUSTRIAL RELATIONS BOARD, consisting of an equal number of represen- 
tatives of emoloyers and employees, and an impartial chairman elected 
by the members of the Board, to investigate all matters of the Code 
relating to hours, wages, and general labor provisions, and to report 
their findings and recommendations to the Code Authority. The desig- 
nated employee representatives shall he truly representative of the 
employees in this industry and shall be selected by such enployees. 

(k) To recommend provisions for a uniform cost system for 
each division of the industry which upon approval hy the Administrator 
and after such notice of hearing as he shall prescribe shall become a 
part of this Code. Any member of the industry shall have the privilege 
of continuing any cost system, or of instituting any cost system suit- 
able and adapted to his particular needs, orovided tha.t the selling 
price arrived at hy the use of any such system shall not be less than the 
cost of that particular article which would be arrived at by the use of 
the uniform cost system recommended by the Code Authority and approved by 
the Administrator. • Any such system ap proved by the Administrator shall 
involve only such elements of cost as may be reasonably necessary to 
assist in the administration and enforcement of this Code. 

9811 



-126- 

(l) To undertake, in conjunction with the Code Authorities 
of rela.ted industries, an investigation of style piracy and to recom- 
mend to the Administrator, within a reasonable period of time, appro- 
priate means for the reflation and contro" of style piracy, which 
recommendations v upon the aporcval of the Administrator and after such 
notice and hearings as he may prescribe, shall become effective pro- 
visions of this Code. 

(m) To make recommendations to the Administrator regarding 
the establishment in this industry of a system of unemployment insur- 
ance, which recommendations, upon the approval of the Administrator 
shall become effective provisions of this Code. 

?. In addition to the information required to be submitted to tte 
Code Authority as set forth in this Article, there shall be furnished to 
government agencies such statistical information as the Administrator 
may deem nocessar^ for the purposes recited in Section 3(a) of the 
National Industrial Recovery Acft. 

8# An appeal from any action by the Code Authority affecting the 
rights of any employer or employee in the industry may be taken to the 
Administrator. 

ARTICLE VII 

Trade Practice Rules 

1. For all numoses of this Code the pets described in this Article 
shall constitute unfair practices. Any member of the industry who shall, 
directly or indirectly, through any officer, enrployee, agent or represen- 
tative, knowingly use, emnloy, or pormit to be employed, and of such un- 
fadr practices shall be guilty of a violation to the Code. 

2. No member of the industry shall use advertising, whether printed, 
radio, display or of any other nature, or other representation which is 
inaccurate in any material particular or in any way misrepresent any com- 
modity, including its use, trade-marl', grade, quality, quantity, origin, 
size, ma.terial content or preparation, or credit terms, values, policies, 
services, or the nature or form of the business conducted. 

3. No member of the industry shall use advertising or selling 
methods or credit terras which tend to deceive or mislead the customer 
or prospective customers,. 

4. No member of the industry shall withhold from' or insert in any 
quotation or invoice any statement that makes it inaccurate in any mater- 
ial particular. 

5» No member of the industry shall brand or mark or pack any 
commodity in any manner which tends to deceive or mislead purchasers 
with respect to the brand, grade, quality, quantity, origin, size, 
material content or ^reparation of such commodity. 



9811 



-1^7- 

6. No member of the industry shall use advertising or other repre- 
sentation which refers inaccurately in any material particular to any 
competitors or their commodities, prices, values, credit terms, policies 
or services. •-^ r — 

7. Ho member of the industry shall publish or circularize un- 
justified or unwarranted threats of legal proceedings which tend to 
harass or have the effect of harassing, competitors or intimidating 
their customers. 

8. No member of the industry shall secretly offer to make any 
payment or allowance of a rebate, refund, commission, credit, unearned 
discount or excess allowance, whether in the form of money or other- 
wise, for the purpose of influencing a sale, nor shall a member 
secretly extend to any customer any special service or privilege not 
extended to all customers of the same class. 

9. Ho member of the industry shall ship cormoditics on con- 
signment or memorandum. 

10. Ho member of the industry shall give, permit to be given, or 
offer to give, anything of value for the purpQ.se of influencing or re- 
warding the action of any employee or agent of another in relation to 
the business of the employer of such employee or the principal or such 
agent without the knowledge of such employer or principal. 

11. Ho-member of the industry shall attempt to induce the breach 
of an existing contract between a competitor and his enxoloyee or 
customer or source of supply; nor shall any member of the industry 
interfere with or obstruct the performance of such contractual duties 
or services. 

12. The maximum credit terms of sale for this industry shall be '* r '" 
3/10 E.O.M.; anticipation to be allo'.7ed at the rate of six per cent 

(6J&) per annum. 

13. Ho member of the industry shall pay directly or indirectly 
any part of the advertising expenses of any purchaser, prospective 
purchaser or their agents. 

14. Ho member of the industry shall accept the return of any mer- 
chandise shipped to a purchaser, nor allow credit therefore, nor exchange 
merchandise where the merchandise has been shi-ypod in accordance with 
specifications a.nd within the specified time and sherc the merchandise 
has been in the possession, actual, cr constructive or the purchaser 

for more than five days. 

15. Ho member of the industry shall sell merchandise belcw his 
own individual cost as computed by the uniform cost system provided in 
Article VI, Section 6 (k) of this Code, except that a member of the 
industry may meet the price competition of another member of the industry 
whose cost, as computed by said uniform cost system, may be lower and 
except that this provision shall not apply to the sale of distressed 
merchandise. 



9811 



-123- 

16. No member of the industry shs.ll dispose of distressed mer- 
chandise at jriccs below the cost of his lowest cost competitor or, if 
such member may himself be the lowest" cost manufacturer, below his own 
individual cost, unless such member notify the Code Authority immediately 
after disposal of such distressed merchandise, along with such informa- 
tion as the Code Authority and the Administrator nay prescribe. General 
fall comaouitive items may not be sold as distressed merchandise during 

tho period of and general 

spring competitive items shall net be cold as distressed merchandise 
during the period of . . 

ARTICLE VIII 

Modif ication 

1. This Code and all the provisions thereof are expressly made 
subject to the right of the President, in accordance with the provisions 
of subsection (b) of Section 10 of the National Industrial Recovery 
Act, from time to time to cancel or modify any order, approval, license, 
rule, or regulation issued under Title I of said Act and specifically, 
but without limitation, to right of the President to cancel or modify 
his approval of this Code or any conditions imposed by him upon his 
approval thereof. 

2. This Code, except as to provisions required by the Act, may 

be modified on the basis of expei*ience or enrnges in circumstances, such 
modification to be based upon application to the Administrator and such 
notice and hearing as he shall specify, ana to become effective on 
approval by the President. 

ARTICLE IX 

Monopolies , Etc. 

No provision of this Code shall be so applied as to permit mono- 
polies or monopolistic practices, or to eliminate, oppress, or dis- 
criminate against small enterprises. 

ARTICLE X 

Price Increases 

Whereas the policy of the Act to increase real purchasing power' 
will be made impossible of consummation if prices of goods and services 
increase as rapidly as wages, it is recognized that "irice increases 
should be delayedo But when made such increases should, so far as 
possible, be limited to actual increases in the seller's costs. 

ARTICLE XI 

Effective Date 

This Code shall become effective on the second Monday after its 
approval by the President. 



9811 



-129- 



EXHIBIT A 

PART 5 

AS REVISED AUGUST 18, 1933 AND ONLY CONTAINING CHANGED PORTIONS 

PROPOSED CODE 

of 

FAIR COMPETITION 

for the 

LADIES' HANDBAG INDUSTRY 

As revised, Ap-olicant 

November 24, 1933. 

■ ASSOCIATED HANDBAG INDUSTRIES OF AMERICA, INC. 

303 Finh Avenue 

New York, N. Y. 

ARTICLE I 

■ • Purposes 

*#* 

ARTICLE II 

Definitions „.,* 

1. The term "Industry" as used herein includes the manufacture of 
ladies', misses' and children's handbags, Toocketbooks and nurses, manuf- 
factured of any material of any kind or nature. 

2 # *** 

r « 

3. *** , . 

4. The term "member of the industry" includes anyone engaged in the 
industry, either as an employer or on his own behalf and either as manu- 
facturer, manufacturing jobber or contractor. 

5. *** . . 

ARTICLE III 

Hours 
*** 



9811 



-ISO- 
ARTICLE IV 
Wago s 

1« Except as hereinafter provided no employee shall he paid at less 
than the rate of thirty-five cents (35«0 per hour when employed within 
Greater N ?w York and the immediate vicinity thereof, nor less than thirty 
cents (30</) -cer hour when employed outside Greater New York and the im- 
mediate vicinity thereof. 

2a Persons 1 earring an occupation shall he naid not less than eighty 
per cent (.30*6) of the minimum wage which previa! s in such occupation, and 
the nunber of such workers shall not exceed fifteen r>er cent (15$) of the 
numher of employees of auy one employer and no person shall he employed as 
a learner for a period in excess c^ three (3) months irrespective of whether 
they are employed by one or mor° employers, 

3. *** 



5a The Code Authority shall he empowered to establish such basic rates 
as they find necessary and UDon the approval of the Administrator and the 
President and after snch notice and hearings as he may prescribe, shall 
become effective provisions of this Code. 

ARTICLE V 

General Labor Provisions 
1 # *** 

2. *** 

3. *** 
A\ * * * 

5. *** 
5 # *** 
7^ *** 

8. *** 
g *** 

10. *** 

11. No member of the industry shall give out work to be performed in 
any home or dwelling place. This -orovision shall not apply to hand beading, 
hand crocheting or hand embroidery a 

9811 



-131- 



12. *** 

13. *** 

ARTICLE VI 
Administration 

1. A Code Authority is hereby constituted to cooperate with the Ad- 
ministrator in the administration of this code. 

2. The Code Authority shall consist of not more than eleven (ll) 
members to he selected from such stoutds and in such numbers as the Ad- 
ministrator may designate and shall he truly representative of the Industry, 

3 # *** 

4 # *** 

5 # *** 

6. *** 
7 *** 

8. "*** 

• ARTICLE VII 

Trade Practice Rules 
t_ *** 

2 t *** 

3 # *%* 

A. *** 



5. *** 

6. *** 

7. *** 
g # *** 
9 **=c 

10. *** 

11. *** 



9811 



-133- 



12. *** 

13. **• 

14. *** 

15. *** 

16. No member of the industry shall disuose of distressed merchandise 
unless such member notify the Oodj-) Authority immediately after disposal of 
such distressed mercnandise, alon - with such information as the. Code Authority 
and the Administrator may orescrijje. Genera], fall competitive items shall 
not he sold as distresfsd merchandise orior to December 26, g^ne^al spring 
competitive items shall not he so' .d as distressed merchandise orior to 
Mothers' Day, and general summer ".oaoetitive items shall not he sold as 
distressed merchandise -orior to jt ly 4. 

ARTICLE VIII 

Modification 

ARTICLE IX 
Monox)Olies f Etc. 

ARTI'.CLE X 
Price Increases 



ARTICLE XI 



Effective Date 



9811 



-133— 

EXHIBIT A 

PART 6 

AS REVISED AUGUST 18, 1933 A1ID OilLY COHTAI1TI1IG CHANGED PORTIOHS 
(Draft of December 8, 1933) 

CODE OF PAIR COMPETITION 

roa the 

LADIES' EAiDBAG INDUSTRY 
ARTICLE I 
PIPBOSE 

ARTICLE II 
DETIiTITIOI-IS 

1. The term "Industry" as used herein includes the manufacture of 
ladies', misses', and children's handbags, pochetbooks, and purses, man- 
ufactured of any material of any kind or nature. 



2 . thro'ugh 



*#* 



*** 



ARTICLE III 
HOURS 

ARTICLE IV 
7AGES 

1. Except as hereinafter provided, no employee shall "be paid at 
less than the rate of thirty-five cents (35.;) per hour when employed 
within Greater Hex? York and the immediate vicinity, thereof, nor less 
than thirty cents (30^) per hour when employed outside Greater New York 
and the immediate vicinity thereof. 

2. Pending further investigation, the Administrator may, under 
exceptional circumstances, and upon such conditions as he may prescribe, 
permit a member of the industry to employ learners at rates below the 
minimum wage hereir established, provided 'oh-.': in no case shall such 
lower rates be lees than eighty per cent (3Gjo) of such minimum wage, 

3. *** 



)811 



-134- 

5. Hereafter, the Administrator may, with the approval of the 
President and after full study and' investigation, establish, as a part 
of this Code, such basic rates for the more skilled classes of employ- 
ees as may be necessary to further effectuate the purposes of the Act. 

ARTICLE V 

GENERAL LA 30R PROVIS IONS 

1. II o person under sixteen years of age shall be employed in the 
industry in any capacity and no person under eighteen (18) years of age 
shall be employed at any manufacturing operation in the industry. 
Within thirty (30) days after the effective date of this Code, the Code 
Authority shall submit to the Administrator a list and description of 
such operations. 

2. through 13. *** 

ARTICLE VI 
ADMIN I STRATION 

1. A Code Authority is hereby constituted to cooperate with the 
Administrator in the administration of this code. 

2. The Code Authority shall consist of not more than eleven (ll) 
members to be selected in the uanner hereinafter set forth: 

(a) Three (3) members shall be appointed by the Associated 
Handbag Industries of America, Inc.; 

(b) Three (3) members shall be appointed by the National 
Association of Ladies' Handbag Manufacturers; 

(c) One (l) member shall be appointed by the Industrial 
Council of Leather Goods Manufacturers, Inc.; . 

(d) One (l) member shall be appointed by the Midwest Handbag 
and Small Leather Wares Association, Inc.; 

(e) One (l) member shall be appointed by the Ladies' Handbag 
Manufacturers of the Pacific Coast; 

(f) One (l) member shall be appointed by the Administrator on 
the nomination of the Labor Advisory Soard, and shall serve without 
expense to the industry; and 

(g) One (l) member shall be appointed by the Administrator 
to represent the Administration and shall serve without expense to 
the industry. 



9811 



-135- 



4. 



o. 



* ## 



##* 



6. Members of the Industry shall be entitled to participate in 
and share the benefits of the activities of the Code Authority and to 
participate in the selection of the members thereof by assenting to and 
complying with the requirements of this Code and sustaining their reason- 
able share of the expenses of its administration. Such reasonable share 
of the expenses of administration shall be determined by the Code Auth- 
ority subject to review "by the Administrator on the basis of volume of 
business and/or such other factors as may be deemed equitable. 

(a) To insure the execution of the provisions of this Code 
and provide for the compliance of the Industry with the provisions of 
the Act and in particular, but without limitation, to receive complaints 
of violations of this Code, make investigations thereof, provide hearings 
thereon a,nd adjust such complaints and bring to the attention of \,he 
proper authorities for prosecution, recommendations and information rela- 
tive to unadjusted violations. 

"■(b) To adopt a constitution, by-laws, and rules and regula- 
tions for its procedure and for the administration and enforcement of 
this Code, and to submit the same to the Administrator for his approval, 
together with true copies of any amendments or additions when made there- 
to, minutes of meetings xilien held, and such other information as to its 
activities as the Administrator may deem necessary to effectuate the 
purposes of the Act. 

(c) To obtain from members of the industry such information 
and reports as are required for the administration of the Code and to 
provide for submission by members of such information and reports as the 
Administrator may deem necessary for the purposes recited in Section 3(a) 
of the Act, which information and reports shall be submitted by members 
of such administrative and/or government agencies as the Administrator 
may designate; provided that nothing in this Code shall relieve any 
member of the' industry of any existing obligations to furnish reports to 
any government agency, IJo individual reports shall be disclosed to any 
other member of the industry or any other party except to sfuch govern- 
mental agencies as may be directed by the Administrator, 



(d) through (j) f 



*** 



8, 



9311 



-136- 

ARTICLE VII 
1TRA LABEL 

1. All merchandise manufactured subject to the provisions of this 
Code shall hear an IDA label to symbolize to purchasers of said merchan- 
dise the conditions under which it has "been manufactured. 

2. Under the powers vested in the Administrator by Executive Order 
of October 14, 193S, and under grant of the necessary authority by him, 
the Cede Authority shall have the exclusive right in this industry to 
issue and sell said labels to the members thereof. 

3. Each label shall bear a registration number especially as- 
signed to each member of the industry by the Code Authority, and shall 
remain attached to all such merchandise when sold to the retail distri- 
butor. 

4. Any and all members of the industry may apply to the Code Auth- 
ority for a permit to purchase and use such iIHA label, which permit to 
use the label shall be granted to them, but only if and so long as they 
conplj' with this Code. 

5. Subject to the approval of the Administrator, the Code Author- 
ity shall establish rules and regulations and appropriate machinery for 
the issuance and sale of labels and the inspection, examination and 
supervision of the practices of members of the industry using such la- 
bels for the purposes of ascertaining the right of such members of the 
industry to the continued use of said labels; of protecting purchasers 
in relying on said labels; and of insuring to each individual member of 
the industry that the symbolism of said label will be maintained by 
virtue of compliance with the provisions of this Code by all other mem- 
bers of the industry using said label. 

6. The charge made for such labels by the Code Authority shall at 
all times be subject to supervision and orders of the Administrator. 

ARTICLE VIII 

TRADE PRACTICE RULES 



*** 



*** 



ARTICLE IX 

liODIEICATIOII 

ARTICLE X 
iiOITOPOLIES, ETC, 



*** 



9811 



-137- 

ARTICLE XI 

PRICE I1ICREAS3S 
*** 

ARTICLE XII 

EFFECTIVE DATE 
*** 

EXHIBIT A 

PART 7 

AS REVISED AUGUST 18, 1933 AID 01JLY COITTAIITIITG CHANGED PORTIOiTS 
(Draft of December 12, 1933) 

CODE OE FAIH COUPETITIOH 

FOR THE 
LADIES' HA1TDBAG INDUSTRY 

ARTICLE I 

PURPOSE 

ARTICLE II 
DEFIHITIONS 

ARTICLE III 
HOURS 



2. Ho person employed in shipping, clerical, or office work, 
■unless he is employed in a managerial or executive capacity and earns 
not less than thirty-five dollars ($35.00) per week, shall "be permitted 
to work in excess of forty (40) hours per week averaged over any one (l) 
month period. 

3. The provisions of this Article shall not apply to watchmen or 
outside salesmen. 

4 *** 



*** 



9811 



-138- 

ARTICL3 IV 

TAPES 

1. Except as hereinafter provided, no employee shall be paid at less 
than the rate of thirty-five (35y) per hour when employed within the City 
of Few York the territory embraced within a radius of thirty-five miles 

of Columbus Circle, nor at less than the rate of thirty (30(0 per hour 
when employed in any other part of the United States. 

2. Pending further investigation, the Administrator may, under 
exceptional circumstances, and upon such conditions as he may prescribe, 
permit a member of the industry b< enp I >j I earners at rates below the 
minimum wage herein established, ■ i jvided that in no case shall such low- 
er rates be less than eighty per cent (80$) of such minimum wage. 

3. *** 

4. *** 

5. Hereafter, the Administ: itor may, with the approval of the 
President and after full study and investigation, and after such notice 
and hearing as he shall prescribe, establish, as a part of this code, such 
basic rates for the more skilled classes of employees as may be necessary 
to further effectuate the purposes of the Act. 

A ft CLE V 

GE NERAL LA30R PRO VI SI PUS 

I. through 10. *** 

II. No member of the Industry shall give out work to be performed 
in any homo or dwelling place, except that this prohibition shall not 
apply to handbeading, handcrocheting or handembroidering, and except that 
hand sewing at home shall be pe. ■ until July 1, 1934, but shall not 
be permitted thereafter. The Code Authority shall, in conjunction with 
such state governments and such departments of the Federal Government and 
such other agencies as the Administrator may designate, study and investi- 
gate the problem of homework in this Industry, and shall make to the Admin- 
istrator recommendations for the effective and appropriate control of such 
homework as is herein permitted. Should the Administrator find it to the 
best interest of the indus ry 31 ■ best interests of labor or other- 
wise necessary to further effectuate the purpi see of the Act, he may fur- 
ther restrict, or wholly prohibit, the >ractice of homework in this indus- 
try. 

12. and 13. *** 

ARTICLE VI 

ADMINISTRATION 

*** 



9811 



*** 



*** 



*** 



*** 



*** 



*** 



-139- 

ARTICLE VII 
MBA LABEL 

ARTICLE VIII 
TRADE PRACTICE RULES 

ARTICLE IX 
MODIFICATION 

ARTICLE X 
MONOPOLIES. ETC . 

ARTICLE XI 
PRICE INCREASES 

ARTICIE XII 
EFFECTIVE DATE 



EXHIBIT A 
: PAUT 8 
AS REVISED AUGUST 18, 1933 AND ONLY CONTAINING CHANGED PORTIONS 

Draft of Dec. 21, 1933 
ARTICLE I 
PURPOSE 



*** 



ARTICLE II 
DEFINITIONS 



*** 



9811 



-14U-. 
ARTICLE I LI 

HOUHS 



*** 



*** 



*** 



*** 



ARTICLE IV 
TJACSS 

ARTICLE V 
GENERAL LAEOR PROVISIONS 

ARTICLE VI 
ADMI IT STRATI ON - 

ARTICLE VII 
NRA LABEL 

ARTICLE VIII 

TRADE PRACT ICE PULES 

Section 1 through 13. *** 

14. No member of the industry shall accept the return of any mer~ 
chandise shipped to a purchaser, nor allow credit therefore, nor exchange 
merchandise vrtiere the merchandise has "been shipped in accordance with spec- 
ifications and within the specified time, nor where the merchandise has 
b.een in the possession cf the purchaser for more than seven (7) days. 

15.& 16. *** 

ARTICLE IX 

MODIFICATION 



*** 



*** 



ARTICLE X 
MONOPOLIES. ETC . 



*** 



9811 



**# 



■*** 



-141- 

ARTICLE XI 
PRICE INCREASES 

ARTICLE XII 
EFFECTIVE DATE 



9811 



-14?-. 



EXHI_BI_T B 

Classified List of Manufacturers 
• '■-. 3 P.rta 



« 



( 



9811 



-143- 



EXHIBIT »B» 
Part 1 



NEW YORK LIST 



PRKS RANOE. 



Retail 

Utd to $1.00 A 

$1.95 and $2.95 B 

$4.95 C 

Over $4.95 D 

CLASSIFICATION 

Manufacturer M 

Manufacturing Jobber J 



9811 



-144- 



NAME 

A & A Bag NoveltyCo., Inc. 

Aeme Handbag Corp. 

Adams, H. A. & Co., Inc. 

Amdur, Lange & Sob el, Inc. 

American Handbag Go. 

Amerloid Company 

Anchor Handbag Com-oany 

Anish, A. 

Annette Handbag Co. 

Annel , B. , Inc. 

Artistic Bag & Neckwear Co., Inc. 

Artistiaue Bag Com. 

Art Style Novelty Co. 

Associated Needlecrafts 

Astorloid Mfg a Co. 

Avon Leather Novelty Co. 

B&S Specialty Co. 

Bagfair, Inc. 

Banita Leather NoveltyCo., Inc. 

Banner Bros., Inc. 

Banwer Mfg. Co., Inc. 

Barclay Handbag Co. 

Barnett Mfg. Co. 

Beaux Arts Lag Co. 

Berman Bag, Inc. 

Bienen-Davis, Inc. 

Biltmore Bag Corn. 

Blatt, A. 

Bloom, Charles, Inc. 

Blum & Marcus, Inc. 

Brickman & Co. 

Br yon & Bandy, Inc. 

C&S Bag Com-oany 

Carnegie, Hattie Shops 

Carole Bags Core. 

Century Handbag Co. 

Character Eags, Inc. 

Charles Handbag, Inc. 

Coblenz & Com-oany 

Cohn & Rosenberger, Inc. 

Colonial Bead Co,, Inc. 

Consolidated ^rim^ine Co. 

Crochet Novelty Mills 

Customcraft Leatner Goods Co. Inc. 



NEW YORK LIST 

ADDRESS 

54 W. 21st St. 
1 W. 34th St. 
36 U. 21s t St. 
693 E= 155 irh St., Bronx 
?P Br o one St. 
505 Court St., Brooklyn 
693 Broadway 
1261 ? roadway 
38 W. 32nd St. 

10 ',/- 33rd St. 
12G9 Broadway 

14 H, 32nd St. 

185 "2nd St., Brooklyn 
8 IE. 12ih L>t. 
17 Hopkins St., Brooklyn 
21.77. 31st St. 

187. Mercer St. 
3Q2 Fi-P'th Ave. 
148 W. 23rri St. 

136 W. 21st St. 

315 Fifth Ave. 
6 W, 13th St. 

32 Union Square 
25 W, 31st Stn 

33 W. 34th St. 
31 E. 32nd St, 

11 -J. 30th St. 
38 W. 32nd S*. 

15 W„ 26th' S*. 
38 W. 32nd St. 
11 W. 30-ch St. 
873 Broadway 



24 W. 


25th St. 


42 E. 


4 r th St. 


10 E, 


33rd St. 


315 Fifth Ave. 


26 Taveriy Place 


22 W« 


32nd St. 


6 W. 


32nd St. 


47 W. 


34th St. 


22 1. 


38th St. 


27 5. 


23ri St. 


54 W. 


21st St. 


40 f. 


17th St. 





CLASSI- 


PRICE RANGE 


FICATION 


A&B 


M 


B 


ii 


D 


n 


A&B 


it 


A 


ii 


A 


n 


B 


ii 


C&D 


ii 


B&C 


it 


B&C 


ii 


B 


ii 


B&C 


ii 


A&B 


ii 


ABC 


ii 


MB 


n 


A 


ii 


BCD 


ii 


B&C 


ii 


ABC 


ii 





J 


A 


M 


B 


ii 


A 


it 


A&B 


it 


B&C 


it 


C&D 


ii 


B 


n 


B 


it 


B 


tt 


B 


1! 


B 


tl 


D 


tt 


B 


II 


C 


tt 


B&C 


tl 


A 


tt 


B 


II 


B 


II 


33 


tl 


BCD 


II 


ABC 


tt 


A 


II 


A&B 


II 


A 


II 



9811 



-145- 



NK7 YORK LIST 



NAME 



ADDRESS 



10-17-35 
PRICE CLASSIFI- 
RANGE CATION 



Dalsheim, M. & Co., Inc. 

DeAlteris, M. 

Deauville Bags Inc. 

Deitscli Bros. 

Dekelman Bag Co . 

Deluxe Handba,r Co. 

Demerer Bros. 

Deamonc. 3ag i'fg. Corp. 

Dickstein Boord & Co. 

Dobuler &. Son Lea.ther Goods Co. 

Dormar Bag Compan}?" 

Dritz-Tra.un Co., Inc. 

Eckhaus, M. H. 

Elk Bag Conroany 

Ella,s Knitting Hills, Inc. 

Emkay Handbag 

Empress Handbag Co. 

Excellent Leather Goods Co. ' 

Feller Bros. 

Fine Arts Novel ty Bag Co. 

Fishbein & Co., Inc. 

Flax, Charles & Son 

Franco-American Leather Goods Co. 

George Frank & Company 

Frank, LI. H.-Rialto Co., Inc. 

French Bag Shop 

Fried & Scheinberg, Inc. 

J & A Friedberg, Inc. 

Friedman, Lobel, Inc. 

Galek, Hi lei 
Gem Ba- Company 
J & P George 
Ginzburg, J. & Sons 
Goldberg, Gus Company 
Gold-flam Leather Goods Co. 
Gold Seal Importers, Inc. 
Goldstein-Rosenf ield, Inc. 
Gra.celine Ho.ndbags, Inc. 

Halberstadt, Inc. 
Hav/es, Elizabeth, Inc. 
Herman Bag Coro. 
Herman Novelty Co., Inc. 
Hi If Bag Mfg. Co., Inc. 
Hobe, Cie 

Hraba, Louis H7. Co., Inc. 
Hortena.u, Alfred J. 

9811 



302 Fifth Ave. ' 


B&C 


M 


38 "J. 32nd St. 


ABCD 


!l 


11 "J. 30th St. 


C&D 


II 


36 S. 31st St. 


C&D 


11 


7 $, 36th St. . 


ABC 


II 


1S2 Madi son Ave. 


B 


ti- 


42 E. 20th St. 


B&C 


ll 


45 "J. 46th St. 


D 


II 


135 M. 17th St. 


A 


II 


12 '.! . 32nd St. 


B 


II 


1225 Broadray 


A&B 


tl 


11 Z. 26th St. 






4 '.7. 32nd St. 


A 


II 


11 ",.\ 30th St. 


' D 


II 


77 Spring St. 


A 


II 


2581 Atlantic Ave. , Bkl; 


irn.BCD 


II 


50 7. 29th St. 


A 


II 


36 E. 10th St. 


A 


n 


675 Broadway 


A 


J 


10 T7. 33rd St. 


B&C 


it 


39 17. 32nd St. 


B&C 


ti 


450 Broome St. 


C&D 


n 


303 Fifth Avenue 


A 


ii 


171 Green St. 


B 


M 


23 E. 26th St. 


A 


ii 


23 E. 48th St. 


A 


it 


45 E. 20th St. 


A 


ii 


971 Third Ave., Bklyn. 


A 


ii 


38 T7. 32nd St. 


B 


it 


781 Prospect Ave., Bron 


K 3 


M 


307 Fifth Avenue 


B 


J . 


347 :,'. 37th St. 


C&D 


M 


102 Prince St. 


A 


M 


35 '.7. 32nd St. 


B 


J 


15 './. 24th St. 


A 


M 


30 S. 33rd St. 


BCD 


ii 


303 Fifth Ave. 


BCD 


J 


20 "7. G3rd. St. 


B 


M 


10 S. 33rd St. 


BCD 


M 


21 E. 67th St. 


B 


n 


6 W. 32nd St. 


D 


ii 


104 S. 4th St., Bklyn: 


A 


n 


333 Fifth Avenue 


BCD 


. n 


566 Seventh Ave. 


D 


ii 


29 E. 19th St. 


ABCD 


it 


39-18 -51st St., TJoodsid 


e A 


ii 



Long Island 



-145- 



NEW YORK LIST 



NAME 



Ideal Leather Suspender Trim. Co. 
Import Bag & lead Corp. 
Irving Handbag Co. 
Israel, Jack, Inc. 

June, D. 

Junvenile Co. , Inc. 

K. G. B. Leather Goods Co. 

Kadin Bros. 

Kaplan & Gordon 

Kasnowitz, Mac & Sons 

Kirk, Varso 

Klein, Louis Co. 

Kle inert Rubber Co. 

Koppel , Jay Company 

Koret, Inc. 

Kraus, Loeb Handbag Co. 

Kregler Leather Goods Co. 

LaRue Bag Company 

Leon Ace Import Co. 

Lesser Bag, Inc. 

Lewis, Nat, Purses, Inc. 

Librick, A. & Sons 

Lincoln Leather Goods Co. 

Lind, Martha 

Lorraine Novelty Mfg. Co. , Inc. 

Lowy & Mund 

Lujean Evening Bags, Inc. 

Lustgarten, B. 

M. S. Novelty Co., Inc. 

Mack, Betty R. 

Made Right Bag Co . , Inc . 

Magid, A. I. Company 

Mailot & Company 

Marino, C. 

Markay Bags, Inc. 

Markel , Inc. 

Maroq dnerie de France 

Marvel Bag Company 

Mastercraft Bags, Inc. 

Maxon Mfg. Co. 

Meisel Company 

Merit Leather Goods Co, 

Metter, M. 

Meyer Leather Goods Co. 

Miller, Venn 

Modern Handbag Co. 

Morgenstern & Brosseau 







10-17-35 


ADDRESS PRICE RANGE 


CLASSIFICATION 


433- Broadway 


B 


M 


15 E. 32nd St. 


BCD 


M 


307 Fifth Ave. 


A 


J 


14 E. 32nd St. 


B&C 


M 


92 E. 10th St. 


D 


M 


40 W. 22nd St. 


A&C 


M 


0; W, 31st St. 


B 


M 


20 TT« 53rd St. 


B 


ii 


6 ¥ s 32cd St, 


ABCD 


ii 


1S8 Oans.1 St. 


A 


Tl 


314 E. ?06th St. 


D 


II 


307 Fif oil Avenue 


A 


J 


485 Fi_ v 'h Avenue 


A 


11 


24 "7. 30th St, 


B 


II 


33 E« 33rd St. 


D 


M 


500 Bs< adway, Bklyn 


A 


ii 


1431 Myrtle Ave., Bklyn. 


B&C 


ii 


9 7. 31st St. 


C&C 


ii 


10 3, 33rd St. 


ABC 


it 


77 Washington Av. Bklyn 


B 


it 


130 W« 30th St. 


D 


it 


334 Bo-very 


A 


ii 


C ff. 32nd St. 


A&3 


ii 


515 Fifth Avenue 


ECD 


it 


352 Fourth Avenue 


B 


ii 


20 3 •"/. 25th St. 


A 


ii 


130 Madison Avenue 


BCD 


it 


165 7. 26th St. 


A 


ii 


38 ¥. 28th St. 


A 


J 


140-10 Franklin, Flushing C 


ii 


110 W. 27th St. 


A 


M 


14 E. 33rd S 4 ". 


BCD 


ii 


12 E. 50th St. 


BCD 


it 


125 Lexington Ave. 


ABC 


it 


30 E. 53rd St. 


A 


it 


15 E. 32nd St. 


C&D 


it 


150 E. 25th Rt, 


A&3 


ii 


29 W. 35th St. . 


A&B 


ii 


10 U. 53rd St. 


C&D 


it 


12 E. S2nd St. 


A&3 


it 


38 T,'. 32nd St.- 


B&C 


it 


14 E. 33rd St. 


B 


it 


24 ¥. 30th St. . 


A 


it 


147 W. 1 25th St. 


A 


it 


27 W. 57th St. 


D 


it 


38 ¥. 32nd St. . 


A&B 


tt 


38 W. 32nd St. 


B&C 


it 



9811 



-147- 



NEff YORK LIST 

NAME 

Moskowitz, Harry & Co., Inc. 
Murray, James C. Co., Inc. 

Nadelhaft Bag Company 

Nadlor Leather Goods 

Nay da Bag Company 

New York Art Bag Company 

New York Bag Co., Inc. 

Nibur, William 

Novelty Handbag Company 

3ur Bag Corporal Lon 

F & R Leather Goods 
Parisian Handbag, Inc. 
Paristyle Bags Company 
Paulbo Company 
Perfection Belt Mfg. Co. 
Pierce Handbag Company 
Pine Brothers 
poneh, G. 

Popular Handbag Corp. 
Powers & Lichtman 
Prime Handbag Company 
Princess Handbag Company 
Pyramid Leather Goods Co, 

Rainbow Leather Goods Co. 

Rath, Wm. C. Company 

Reiman, J. 

Riehloy Handbag Company 

Ritter & Daachman 

Ritter & Ritter 

Robbins & Weitz, Inc. 

Roodelheimgr, Edgar, Inc. 

Rose* Leather Goods 

Rose, S. B. Company 

Harry Rossnfeid 

Roth, Harry 

Roth, Max 

Rout, Rosenthal Company 

Rubin Leather Goods Corp. 

Rubin, T. 

Ruby Bags, Inc. 

Sachs Brothers 
Salon Novelty Bags Inc. 
Saniton Specialty Co., Inc. 
Schoonholtz & Weeks, Inc. 
Schwab & Rebell 
Schwarts-^feisberg Handbag Co. 



ADDRESS 

1225 Broadway 
250 S. 43rd St. 

11. W. 30th St. 
130 tf. 30th St. 
11. W. 30th St. 
4 W. 32nd St. 
22 W. 32nd St. 
2432 Broadway 
10 E. 33rd St. 

228 Grand St. , Bklyn. 



221 Powell St., Bklyn 

7 W. 30th St. 

.20 W. 33rd St. 

22 W. 32nd St. 

38 W. 32nd St. 

9 W. 31st St. 

1421 E. N. Y. Ave., Bklyn 

32 Union Stjuare 

28 ¥. 25th. St. 

53 ¥. 23rd St. 

252 penna. Ave., Bklyn 

303 Fifth Avenue 

6 W. 32nd St. 

30 E. 10th St. 

31 E. 32nd St. 
.3 W. 29th St. 
14 E. 33rd St, 
3 W. 29th St. 

.14 E, 33rd St. 
38 W. 32nd St. 
303 Fifth Avenue 
693 Broadway 
225 Fifth Avenue 
130 Madison Avenue 

14 E. 33rd St. 
491 Broadway 
22 W. wqnd St. 
6 W. 32nd St. 
?0S E. 19th St. 
180 Madison Avenue 

79 Fifth Avenue 
19 E. 22nd St. 
148 W. 23rd St. 

15 E. 32nd St. 
126 W. 46th St. 
15 E. 32nd St. 





10- 


-17- 


-35 


PRICE RANGE 


CLASSIFICATION 


A 






J 


ABCD 






M 


C&D 






If 


B 






it 


B 






it 


A 






it 


A&B 






it 


A&B 






it 


C 






n 



A 



A 


ir 


A 


ii 


BCD 


ti 


ABC 


H 


A 


II 


BCD 


It 


A 


tl 


B 


It 


A 


tt 


A&B 


J 


A 


M 


A 


it 


BCD 


tt 


A 


tt 


BCD 


it 


B&C 


it 


A 


it 


B&C 


it 


B 


tt 


B 


it 


D 


J 


A 


M 


A&B 


tt 


B 


it 


A 


ii 


A 


it 


B 


n 


B&C 


it 


A 


ii 


B 


it 


A 


tt 


A 


ii 


A&B 


it 


C&D 


tt 


D 


tt 


A&B 


tt 



9811 



-143- 



NEW YORK LIST 



NAME 



Seidman & Glickstein 

Service Handbag Company 

Siegel, A, L. Co., Inc. 

Silver, M. 

Sims, J. 

Sloane Bros. 

Spring Crochet Company 

Stair, David 

Stanley & Stanley, Inc. 

Stein-Drew Corporation 

Steinman Co. , Inc. 

Steinman, Louis I. 

Stone, Harry S., Inc. 

Style Bag Company 

Superb Leather Goods Company 

Tailored Handbag Company 
Texloid Handbag Company 
Triangle Leather Goods Company 

U. S. Pillow Corporation 
Unique Style Alligator Bag Co. 

Vanity Pair Bag Co., Inc. 
Variety Leather Goods Corp. 
Vienna Bag Co., Inc. 
Vogue Leather Goods Corp. 

Wagman & Company 
Warner Manufacturing Company 
Weinman, Max, Inc. 
Weisberg, N. Co., Inc. 
Wolfe, M. E. Company 
Wollison Company, Inc. 







10-17-35 


ABESESS 


PRICE RANGE 


CLASSIFICATION 


93 Crosby St. 


A 


If - 


12 ff„ 32nd St. 


A 


ii 


20 W. 22nd St. 


A 


u 


149 Ashfcr-d St. , 


Bklyn. A 


ii 


39 W, 32nd St.. 


B 


ii 


14 Z. 32nd St. 


A&B 


ii 


50 Spring St. 


A&B 


n 


35 W~ 32nd St. 


A 


ii 


325 Fif oh Avenue 


C&D 


ii 


1214 Broadway 


B 


J 


20 '.7. 33rd St. 


BCD 


M 


2 r ' 3 10:h St. 


A 


it 


6 W. r '"'-a St. 


C&D 


n 


24 7, 35th St. 


A 


ii 


220 Alabama Ave., 


, Bklyn. A 


it 


19 S. 48th St. 


C 


J 


307 Fifth Avenue 


A 


n 


608 Broadway. 


A 


M 


11 E. 26th St. 


A 


M 


147 T 7. 26th St. 


B&CD 


ii 


11 1 Broadway 


B 


J 


39 W. ■ : St. 


C&D 


M 


34 "7. 46 bh St. 


B&C 


it 


114 w. 30th St. 






133 W. 25th St. 


A 


it 


49 E. 3th St. 


A&B 


ii 


46 W. 20 th St. 


A 


ii 


110 W. 17th St. 


B&C 


it 


303 Fifth Avenue 


ABC 


J 


42 W. 33rd St. 


C&D 


M 



( 



-149- 
EXHI3IT "B" 

PART 2 



OUT OF TOW LIST 



PRICE HANGS 



■Kctail 

Up to $1, 00 A 

$1. 95 raid $2. 95 B 

$4. 95 C 

Over $4. 95 ' . . D 



CLASSIFICATION 

Lianuf acturc r. . » ,M 

lianuf adjuring Jabber J 



9811 



NAME 

Aarenau & Wolf, Inc. 
Adolph Leather Goods 
Aetna Leather Novelty 
Allen Leather G-oods Co. 
Amity Leather Products Co 
Arrow Leather Goods Co. 
K. Atsales 

D. Balazs 
L. G. Balfour Co. 
Beacon Leather Goods Co. 
Better Bag Co. 
Black Mfg. Co. 
Alphonse Bollock, Ltd. 
Bosca, Inc. 

Hugo Bosca Co . • • ■ 
Braided Fabric Co. ••• 
Max Brill's Sons, Inc. 
Brynmore Leather Gds- Co. 
The Buckeye Leather Co. 
Chas. Burstein & 3rc . 

Cameo Hand Bag, Inc. 
Angelos Cassaris 
Century Leather Gds. Co. 
Nicholas Chakoutis 
Classy Leather Gds. Corp. 
The Coed Hand Bag Co. 
Concey Handbag Co . 
Cordova Shops, Inc. 
Cornell Mfg. Co. 
Crescent LeaTher Goods 

Crystal Co. 
Crystal Leather Gds. Co. 

Davis-Alberts Co. Inc. 
The Dorothy Designs 
Andrew Dougenis 

Eagle Leather Goods 
Economy Froducts Corp. 
Eisman Kaye Co . 
Elite Leather Goods Co. 
Enger-Kress Co. 
Enterprise Accessories, I 
Equitable Handbag Co. Inc. 

Fancy Leather Goods Co. 
Fancy Leather Goods Co. 
Fashion Bag & Leath.Nov. 

9811 



-150- 












OUT OF TOWN 


LIST 




CLASS! 








Price FICA- 


ADDRESS 




CITY STATE RANGE TION 






Fall River, 


Masa . 


B&C 


M 


3641 V;est 25th Street 


Chicago , 


111. 


A 


n 







Union City, 


N.J. 


A 


n 






Al lento wn , 


Pa. 


A 


ti 


4th Ave. at Locust 


St. 


West Bend, 


Wis. 


BCD 


n 


325 3. Market Stree 


t 


Chicago, 


111. 


A&B 


ii 


513 B. is ton Street 




W. Lynn, 


Mass. 


C&D 


n 


251 Post St. S 


an 


Francisco , 


Cal. 


C&D 


ii 







Attleboro, 


Mass . 


D 


ii 







Bridgeport , 


Conn. 


A 


ii 


Smith & 3rd St. 




Newburgn, 


N.Y. 




n 


19-21 W. 4th St. 




Fennsburg, 


Pa. 


A 


n 


783 Mission St. S 


an 


Francisco , 


Cal. 


B&C 


n 






Marion, 


Ohio 


A&B 


n 




Springfield, 


Ohio 


BCD 


it 




Frovidence, 


R.I. 


A 


it 


U-l_ 


Pi 


.ttsf ield, 


Mass. 


BCC 


it 


20 Jelin Street 


New Brunswick, 


N.J. 


AB 


ti 


Chestnut Street 


Coshocton, 


Ohio 


D 


it 







East on, 


Fa. 


ABC 


ti 


Kirk Bldg. 


Bridgeport , 


Conn. 


A 


n 


2 Murray- Street 




, W . Lynn , 


Mass . 


D 


n 


6235 Father .jon Ave. 




Chicago , 


111. 


C 


n 


49 Wyraan Street 




W . Lynn , 


Mass. 


BC 


n 


7-29 C a naJ St. 


Mi 


ddletown, 


N.Y. 


A 


it 


213 Institute Place 




Chicago, 


111. 


AB 


ti 





Lc 


ng Island, 


N.Y. 


D 


n 


1399 West Ave. 




Buffalo , 


N.Y. 


BC 


n 


21-27 Gordon Ave. 




Providence, 


R.I. 


A 


it 


15 Snow Str-. h 




Providence , 


R.I. 


AB 


it 


85 Vroom S u . 


Jersey City, 


N.J. 


CD 


n 


320 W. Adams St. 




Chicago, 


111. 


ABC 


it 


99 Chauncy 3t . 




Boston, 


Mass . 


A 


J 


507 Textile Tower 




Seattle , 


Wash. 


ABC 


M 


46 Wyraan St. 




Lynn , 


Mass. 


A 


n 


173 Summer Street 




Boston, 


Mass. 


A 


it 


512 S. Feoria St. 




Chicago, 


111. 


B 


it 


23 S. Franklin St. 




Chicago , 


111. 


B 


it 


42 Summer St. 




Boston, 


Mass . 


AB 


ii 







West Bend, 


Wis. 


BCD 


tt 


nc.38 School Street 




Greenfield, 


Mass . 


C 


n 


191 Redmond St. 


Ne 


w Brunswick, 


N.J. 


A 


ti 


305 Grant Ave. 


San Francisco, 


Cal. 


BCD 


it 


36 Hopkins Place 


Ba 


ltimore, Md . 




A 


it 


Co. 31 E.Kinney St. 


Newark, 


N.J. 


A 


ii 



-151- 



OUT OF TOWN LIST 



NAME 

Fashion Ladies Handbag Co. 

Forst & Co. 

M. J. Fox & Co. 

H. B. Franklin 

Franklin Bag Co . 

Ganson Mfg. Corp. 
Geffen-Weene Bag Co. Inc. 
Gindoff & Grunther , Inc. 
Gitlin Bros.& Rash, Inc. 
Moe Gleicher 
G. R. Godfrey Co. 
Goldberg Bros. Handbags , Inc. 
Goldberg & Seltzer, Inc. 
Goldsmith Bros . 
B.M.Goldstein & Son 
Gould Hand Bag Co. 
Grace-Mae Leather Goods Co 
Irving Guberman Bag Co. 



ADDRESS 



CITY STATE 



Cla 
ssi 

■ -fi 
Price- - ca 
STATE H ahee ti on 



234 S. Market St. Chicago, 111. 
253 N. 12th St. Philadelphia, Fa. 

N.E.Fratt & Greene Sts. Baltimore, Md. 
130 Essex Street Boston, Mass. 
26 Wingate Street Haverhill, Mass. 



365 Market Street San Francisco, 

111 Beach Street Boston, 

19 S. Plainfield Ave.Flainfield 



232 V.. 11 Street 
972 Springfield Ave 
14 Pearl Street 
Liberty Street 
12 No . Cherry St . 
315 Linden St. 
709 Mission St. 

30 S. Wells St. 
110 Lincoln St. 



Philadelphia 
Irvington, 
Gardner, 
Newburgh 
Foughkeepsie , 
Allentown, 
San Francisco , 
Boonton, 
Chicago, 
Boston, 



Cal. 

!/■ ass. 

N.J. 

Fa. 

N.J. 

Mass. 

N.Y. 

N.Y. 

Pa. 

Cal. 

N.J. 

111. 

Mass . 



B 

ABC 

ABC 

AB 
A 

B 
AB 
A 
AB 
D 
BC 
A. 
AB 
ABCD 
AB 
B 
B 
A 



M 
ii 

it 

ii 

n 

M 
n 

ii 

n 

ii 

n 

n 

n 

ii 

ii 

ii 

ii 



Hamilton Leather Goods Co 
Harlic Bag Co . 
Harpley Industries 
Harrison Leather Goods Co 
Heimer Bros.& Frankel 
Herz & Kory 
High Acres Mt. Guild 
Hood Rubber Co. Inc. 
Hudson Leather Gds.Co.Inc 



27 S.Franklin St, 
Webster St. 
22 Elkins St. 
231 Harrison Ave. 

230 Fine St. 



Boyertown, Fa- BC 

So.Norwalk, Conn. A 

So. Boston, Mass. A 

Boston Mass. A 

Garnerville, N.Y. A 

Williamsport , Fa. AB 

Flov/ery Branch, Ga. A 

Watertown, Mass. A 

Nyack, N.Y. A 



M 
it 

ii 

it 

ii 

n 

ii 

ii 

ii 



Ingber & Co. Inc. 1307 Market St. 

International Leath.Gds .Co . 141 II. 11 Street 



Philadelphia, Fa. BC 

Philadelphia, Pa. AB 



Justin Leather Goods Co 



Nocona, 



Tex. 



B 



K & K Leather Goods Co. Inc. 1 Erookside Ave. 



Ben j . Kash 

Ben j . Katz 

Keller Bros . 

Kewar Co . 

Kreuter Leather Goods Co. 



407 E. Pico, St. 
Washington St. 
311 Mountain 3d. 



2418 W. 9 Street 



La Mode. Handbag Co. 226 S. Wells St. 

Landis Leather Goods, Inc. 284 State St. 

LaSalle Hand Bag Co. Inc. 15 Court land St. 

Lawson Studios 93 Mass. Ave. 

Leather Fabric Creations, Inc . 

Licht & Kaplan, Inc. 35 Lander St. 

Lieberson Novelty Co. 119 S. Wells St. 



New Brunswick, N.J. A 

Los Angeles, Cal. BC 

Nyack,' N.Y. A 

Union City, N.J. BCD 

Gloversville, N.Y. A 

Los Angeles, Cal. B 

Chicago, 111. BC 

Perth Amboy, N.J. AB 

New Brunswick, N.J. AB 

Boston, Mass ABC 

Trenton, N.J. A 

Newburgh, N.Y. A 

Chicago, 111. BC 



9811 



-152- 



OUT OF TOWN LIST 



NAME ADDRESS 



CITY 



STATE 



DLAS- 
Price SIFI- 
Range CATION 



Anna B. Locke 
The Locktite Co. 
Luce Mfg. Co . 
James H. Lunn Co. 



34 Hurlbut St. 
117 Blucker St. 
618 Delaware St. 
1771 Union St. 



Albany, N.Y. 

Blovers'ville, N.Y. 

Kansas City, Mo. 

San Francisco, Cal. 



Makewell Leather Goods Co 
H. Margolin & Co . 
Mastercraft Leether Goods 
Maurice Handbag Co. 
The Meeker Co. 

Merrimack Valley Bag Co. 

Meyers Mfg. Co. 

Michel, Maksik & Feldman, Inc. «X-». 

Midwest Ladies 'Handbag Co. 402 So 



Pennsburg, 

380 River Street Fitchburg 
Center & Cutler St s .Waukesha, 



30 E.Randolpn St 



Market St 



Chicago, 

Joplin, 

Haverhill', 

Norwalk, 

Clinton, 

Chicago, 



Mirro Leather Goods Co. 402 S. Market St. Chicago, 
Molomut Hand Bags, Inc. 150 Fox Street Elmira, 
Morgan Specialty Co. 719 S.Los Angeles St. Los Angeles, 
Morris, Mann & Reilly, Inc. 320 W. Adams St. Chicago, 

Mountain Handcrafts Co. Inc. Biltmore, 

Sol Mutterperl, Inc. New Bedford, 



National Ladies Handbags, Inc. 101 Taylor St, 

Charles W. Belson & Co. Inc. 

New Hampshire Novelty Co. 18 Hanover St. 

Nocona Leather' Gbods Co. 

Novelty Bag Co.' 98 Fhoenix Row, 

Nu-Mode Bag Co. 47-51 Day St. 



Paragon Bag Co. Inc. 
Paragon Novelty Bag Co. 
Paramount Bag Co. 
Joseph Fasthoff 
Pat Bags, Inc. 
^Petite Novelty' Co. 
^Philip Bag Co. 
Phoenix Novelty Co. 
Princess Hand Bag Inc. 

R & K Leather Goods Co.Inc 
Radio Kimmerl Corp. 
Raymond Mfg. Co. 
Reo Leather Goods Co. 
Resnick Bros . 
Julius Resnick, Inc. 
Robbins & Staufert 
Royal Leather Goods 
Royal Leather Novelty Co. 
C .F.Rumpp & Sons 
Frank A. Rupert 



102 S.Williams St. 
241 Winter St. 
1561 Milwaukee Ave, 
310 S. Meadow St. 
9 Little Burnet St, 
241 Winter St. 
25 Hale St. 
170 Elm St'. 



Springfield, 
Pulaski , 
Manchester, 
Nocona, 
Haverhill, 
So .Norwalk, 

Schwenksville, 
Newburgh, 
Haverhill, 
Chicago, 
Richmond, 
New Brunswick, 
Haverhill, 
Haverhill, 
1 Bridgeport , 



291 New Brunswick 

421 E. Miner Ave. 
9 Morrill St . 
689 N.Clinton St. 
720 N.Clinton St. 
229 S. Market St. 
77 St. Francis St. 
3419 Rutger St. 
5th & Cherry Sts. 
31 Union St. 



Ave .Per th Amboy . 
Sussex, 
Stockton, 
Elizabeth, 
'Syracuse, 
Syracuse, 
Chicago, 
Newark, 
St .Louis , 
Philadelphia, 
Gloversville , 



Pa. 

Mass, 

Wis. 

111. 

Mo. 

Mass , 

Conn, 

Mass. 

111.' 

111. 
N.Y. 
Cal. 
111. 
N.C. 
Mass . 

Mass. 

N.Y. 

N.H. 

Tex. 

Mass. 

Conn. 

Pa. 
N.Y. 
Mass . 
111. 

Va 

N.J. 

Mass. 

Mass. 

Conn. 

N.J. 
N.J. 
Cal. 

N.J. 
'N.Y, 
N.Y. 
111. 
N.J. 
Mo. 
Fa. 
N.Y. 



C 
AB 

A 
AB 

ABC 

BCD 

BC 

A 

BCD 

A 

A. 

BC 

AB 

B 
B 

AB 
ABC 
B 
A 

A 

A 

B 

AB 

A 

A 

A 

A 

A 

A 

ABC 

A 

A 

A 

A 

A 

A 

AB 

A 

A 

A 

BC 

A 

A 

BCD 

B 



M 
n 

ii 

'ii 



ii 
n 
n 
n 
n 
ii 
it 
n 
n 

M 
ii 

n 

n 

n 

n 

n 
n 
n 
ii 
ti 
n 

ii 
n 
ii 
n 
ii 
n 
n 
n 
n 

ii 
it 
ii 
ii 
ii 
n 
ii 
n 
ii 
ii 
n 



9811 



-153" 



OUT OF TOWN LIST 



CLAS3I-, 



NAME 



Otto W. Schmidt 

Seger ■ s 

Sel-Wel Mfg. Co. 

Self Style Hand Bag Co. 

Somer Bags 

Specialty Leather Goods Co. 

Springfield Leath.Frod.Co . 

Stamford-Raymond Mfg. Co. 

Standard Novelty Co. 

Stanley Handbag Co. 

Strand Leather Goods Co. 

Style Craft Bag Co. 

Stylecraft Leather Goods Co 

Stylecraft Leather Goods Co 

Sunshine Studio 

Supreme Leather Goods Co. 

Texas Tanning & Mfg. Co. 
Theobalt & Ehlert Co. 
Three Mountaineers 
The Treasure Chest, Inc. 

Uneeda Belt Co . 
United Bag Co. 
Universal Hat Works 
Universal Leather Goods Co. 

Variety Handbag Co. 
V a ssar Bag Co. Inc. 
Vin Clair Mfg. Co. 
Virginia Art Goods Studios 
Joseph Virzi 



Wnv. C. Waugh Co. Inc. 
Well Made Lea. Nov. Co 
Western Bag Craft 
Wilcox Co. 
E. J. Wilkins 



Inc 









FtCA- 


ADDRESS 


CITY STATE PRICE tion 






RANGE 


942 Market St. 


San Francisco, 


Cal. 


3C M 


28 E. Ridgewood Ave 


.Ridgewood, 


N.J. 


B " 


10 Ni Washington 3t 


.Boston, 


Mass . 


A " 


340 Manhattan Ave. 


Union City, 


N.J. 


A " 


310 Washington St. 


Bridgeport , 


Conn. 


A " 


64 Beach St. 


Boston, 


Mass . 


A " 


110 W. Main St. 


Springfield, 


Ohio 


BCD " 


820 Mission St. 


San Francisco, 


Cal. 


AB " 


324 Front St. 


Flainf ield , 


N.J. 


A " 


N.E.8th & Arch St. 


Philadelphia, 


Fa. 


A " 


120 Sawyer St. 


New Bedford, 


Mass. 


AB " 


1? N. W. 3rd St. 


Miami , 


Fla. 


A " 


. _ 


Scronton, 


Fa. 


ABC " 


. Inc. 


Bridgeport , 


Conn. 


A " 


131 Sanford Ave. 


Flainfield, 


N.J. 


A3 " 


. 150 Bay St. 


Jersey City, 


N.J. 


AB " 





Yo akam , 


Tex. 


AB M 


1445 N. 5th St. 


Milwaukee, 


Wis. 


A " 


-__— 


Asheville, 


N.C. 


A H 


: . .. 


Asheville, 


N.C. 


A " 


120 Water St. 


Newburgh, 


N.Y. 


A " 


91 Federal St. 


Lynn , 


Mass. 


A " 





Linden, : 


N.J. 


A " 


538 S.Dearborn St. 


Chicago , 


111. 


BC " 


1028 Filbert St. 


Philadelphia, 


Pa. 


A " 





Stroudsburg, 


Fa. 


BCD ■ 


149 N. 12th St. 


Philadelphia, 


Fa. 


B » 


1308 Cnurch St. 


Lynchburg, 


Va- 


BCD " 


1220 Maple Ave. 


Los Angeles, 


Col. 


BCD " 


686 Mass. Ave. 


Cambridge, 


Mass 


A " 


. 34 Norwich Ave . 


Colchester, 


Conn. 


A " 


119 E. 23rd St. 


Los Angeles , 


Cal. 


BC " 





Athol, 


Mass. 


A " 





Gloversville, 


N.Y. 


AB " 



9811 



-154- 

EXHIBIT »B" - FART 3. 
CONTRACTORS 



NAME 

J. Abrahams & M. Wilensky 
Wm. Ammerman & Sons 
Anchor Handbag Company 
Joseph Arner 
Art Novelty Mfg. Co. 
Artistic Eag & Neckwear Co. 

Inc. 
K. Atsales 

Avon Bag Company, Inc. 
Avon Leather Novelty, Inc. 

Barclay Handbag 

Meyer Benn 

Better Bag. Company 

Black Mfg.. Co", 

S . Bonamo 

Antone Bontos 

Mrs. W. S .. Bowen 

Broadway Handbag 

Buoyant Bag Company 

Buy American Novelty Company 

C. & G-. Handbag Company 

T. C»roloni 

Angelos Cassarsis 

F. Castillo 

John Celestri 

Century Novelty Corp. 

Nick Chakoutis 

Fhil Cohen 

Columbia Purse Company 

H . Co rman 

S. Cost an zo 

F. Cozzolino 

Creative Handbag Company 

John Cretakos 

Customcraf t 

Dominick de Gaetano 
John Dignoti 
Liboria di G-regoria ' 
Ignazio di Silvestre 
Dostal & Company 
Andrew Dougenis 

Edward Elias 

Henry Euler 

Excellent Leather Goods 



ADDHESS 

34 Cottage St. 
8 Terrace Avenue 
693 Broadway 
119 Attorney St. 
6 E. 27th St. 

1209 Broadway 
513 Boston St. 
162 Chestnut St. 
9W. 31st Street 

8 W. 18th St. 
416 W. Front St. 
Smith & 3rd Sts. 
Fourth Street 
203 E. 107th St. 
32 Flint St. 



CITY 



STATE 



136 W. 22nd St. 
40 W. 28th St. ' 
15 W. 24th St. 

15 W. 16th St. 
151 Spring St. 
2 Murray St. 
21 W. 111th St. 
1708 86th St. 
407 S. Jefferson St, 
49 Wyqaan St. 
775 - 6th Avenue 
15 W. 24th St. 
6113-19th Avenue 
2 Ler.ox Avenue 
341 State "Street 
31 Thompson Avenue' 
71 Williams Avenue 
40 W. 17th St. 

7714-13th Ave. 
199 Avenue T 
3217 Broadway 
148 Bay 22nd St. 
218-25 132nd Ave. 
46 Wyman St. 

34 S. 10th St. 
404 Fourth Avenue 
36 E. 10th St. 



Poughkeepsie 


N. 


Y. 


Hasbrouck Ht . 


N. 


J. 


New York 


N. 


Y. 


New York 


N. 


Y. 


New York 


N. 


Y. 


New York' 


N. 


Y. 


West Lynn 


•Mass. 


Springfield 


Mass . 


New York 


N. 


Y. 


New York 


N. 


Y. 


Flainfield 


N. 


J. 


Newburgh 


N. 


Y. 


Pennsburg 


Fenna 


New York 


N. 


Y. 


West Lynn 


Mass. 


We'averville 


N. 


C. 


New York 


N. 


Y. 


New York 


N. 


Y. 


New York 


N. 


Y. 


New York 


N. 


Y. 


Concord 


B. 


I. 


West Lynn 


Mass . 


New York 


N. 


Y. 


Brooklyn 


N. 


Y. 


Orange ' 


N. 


J. 


West Lynn. 


Mass. 


New York 


N. 


Y. 


New York 


N. 


Y. 


Brooklyn 


N. 


Y. 


Fleasantville 


N. 


Y. 


New Haven ' 


Conn. 


L. I. City 


L. 


I. 


East Lynn 


Mass. 


New York 


N. 


Y. 


Brooklyn 


N. 


Y. 


Brooklyn 


N. 


Y. 


Astoria LI 


N. 


Y. 


Brooklyn 


N. 


Y. 



Springfield Gardens, L.I. 
Lysnn Mass 



New York 


N. 


Y. 


New York 


N. 


Y. 


New York 


N. 


Y. 



9811 



•155-* 



CONTRACTORS 

NAME 

F. & Leather Goods Co. 

J . Fasula 

Fine Make Leather Goods Co. 

F. Fisch 

Louis Fieischman 

Fleischman & Kniberg 

Franklin Bag Company 

Fried & Scheinberg, Inc. 

Fulton Leather Goods Co. 

Philip Gaber 
Laurence G~eta 
Gale Leather Goods 
Gindoff & Grunther 
Goldfarb & Goodstat 
Goldflam Leather Goods Co. 
D. Golia 

H. & b! Novelty 
Charles Hacker 
Hudson Leather Goods Co. 
H. Hunger -■ 

Alphonso Inclima 
Independent Leather Goods 
S. Isaia 

Jason -Handbag Company 
Juvenile Company. Inc. 

K.G.&.B. Leather Company 
Kafka. & Kleinman 
Samuel Katz 
Kosiov 4 Victor 
Kraus-Loeb Handbag Company 
G. Kregler 

Lee Handbag Company 
Levy & Singer 

A. Librick & Sons 
Lowy & Mund 

B. Machlus Leather Goods 
Elizabeth Mack 

Made Right Leather Goods Co, 
Majestic Handbag Company 
Mannb Bros. 
Phillip Manno 



ADDRESS 



CITY 



STATE 



233 Powell St. 


Brooklyn 


N. 


Y. 


1743 -62nd St. 


Brooklyn 


N. 


Y. 


115 W. 30th St. 


New York 


N. 


Y. 


224 Livingstone St . 


Brooklyn 


N. 


Y. 


420 E. 93rd St. 


Brooklyn 


N. 


Y. 


145 Spring St. 


New York 


T,T 


Y. 


104 Franklin St. 


Haverhill 


Mass. 


45 S. 20th St. 


New York 


N. 


Y. 


313 Fulton St. 


Brooklyn 


N. 


Y. 


940 -39th St. 


Brooklyn 


N. 


Y. 


107 .Leach St . 


Yonkers 


N. 


Y. 


98 Murray St . 


Newark 


N. 


J. 


19 S. Flainfield Ave.Flainfield 


N. 


J. 


37 W. 20th St. 


New York 


N. 


Y. 


15 W. 24th St. 


New York 


N. 


Y. 


■316 St. John St. 


New Haven 


Conn. 


54 W. 21st St. 


New York 


N. 


Y. 


582 Evergreen Ave. 


Brooklyn 


N. 


Y. 


85 S. Broadway 


Nyack 


N. 


Y. 


105 S. First St. 


Brooklyn 


N. 


Y. 


611 Grand Ave. 


New Haven 


Conn. 


16 Burd Ave. 


Nyack 


N. 


Y. 


1559-79th St. 


Brooklyn 


N. 


Y. 


37 W. 20th St. 


New York 


N. 


Y. 


40 W. 22nd St. 


New York 


N. 


Y. 


'9 W.' 31st St. 


New York 


N. 


Y. 





Otisville 


N. 


Y. 


430 Keap St. 


Brooklyn 


N. 


Y. 


1209 Broadway 


New York 


N. 


Y. 


500 Broadway 


Brooklyn 


N. 


Y. 


1481 Myrtle Ave. 


Brooklyn 


N. 


Y. 




Waterbury 


Co 


tin. 


36 W. 29th St. 


New York 


N. 


Y. 


334 Bowery 


New York 


N. 


Y. 


209 W. 26th St. 


New York 


N. 


Y. 


693 Broadway 


New York 


N. 


Y. 


945 -71st St. 


Brooklyn. 


N. 


Y. 


.110 W. 27th St. 


New York 


N. 


Y. 


132 W, 21st St. 


New York 


N. 


Y. 


723 Sip Street 


Union City 


N. 


J. 


240 -25th St. 


Brooklyn 


N. 


Y. 



9811 



-156- 



CONTRACTORS 

NAME 

Goper Mas gal 

Joe Matra 

Pasquale Messina 

M. Metter 

Mintz & Re snick, Inc. 

Model Bag Company 

Model Novelty Company 

Mohawk Leather Goods Co. 

Lillian Mueller 

M. Madelman 
Nemeth & Adam, Inc. 

Mrs. Collette Owens 

George Padolny 

Paris-ian Handbag Company 

Paroly Bag Company 

J. Pasthoff Luggage Shop 

Peppy 

Alonzo Piombino 

Popular Handbag Company 

Amelia Ramp ol la 

R. M. Reader 

Real Art Handbags, Inc. 

Prank Regulsky 

M. Ri enter 

Rivoli Manufacturing Company 

Simon Robbins 

I. Ro gal sky 

M. Rosen Bag Company 

Rosenswein Leather Goods 

T. Rubin 

Russian Hand Made Embr. Works 

S & K. Bag Company 

Sal vat ore Novelty Company 

0. Schmidt 

Schwab & Rebell 

Sel-Wel Mfg. Co. 

P. Shapiro 

Shenfield Leather Goods 

Marcus Sherman 

M. Silver 

Mary Sokoloff 

Spring Valley Leather Goods 

Star Handbag Company 

Charles Stein 

Albert P. Stewart 

Louis I. Steinman 

Sun Novelty Company 



ADDRESS 



CITY 



STATE 



235 B 


rock Avenue 


Bronx 


N. 


Y. 


1562 


- 66th St. 


Brooklyn 


N. 


Y. 


2412 


Hoffman St. 


New 


York 


N. 


Y. 


24 W. 


30th St. 


New 


Ycrk 


N. 


Y 


5 W. 


31st St. 


New 


York 


N. 


Y. 


30 f. 


31st St. 


New 


Ycrk 


N. 


Y. 


22 W. 


21st St. 


New 


York 


N. 


Y. 


20 E. 


12th St. 


New 


York 


N. 


Y. 


119 Winfred Ave. 


Yonkers 


N. 


Y. 


1209 Broadway 


New 


Ycrk 


N. 


Y. 






Ronkokoma 

Hoi iiinH-n c* 


L. 

N. 
K. 


I. 

C 
Y. 






52 W. 


15th St. 


■Ne- 


Ycrk ■ 


40 N. 


4th St. 


Phila. 


Penn. 


12 w. 


18th St. 


New 


Ycrk 


N. 


Y. 


1561 


Milwaukee Ave. 


Chicago 


111. 


58 ¥. 


25th St. 


New 


York 


N. 


Y. 


2407 


Trotman Avenue 


Bronx 


N. 


Y. 


28 W. 


25th St. 


New 


Ycrk 


N. 


Y. 


114-17 45th Avenue 


Flushing 


L. 


I. 


85 Ma 


.in St. 


DobbsPerry 


N. 


Y. 


134 T, 


'. 29th St. 


New 


York 


N. 


Y. 


45 Newell St. 


Bro« 


;klyn 


H. 


Y. 


52.14 


Third Avenue 


Brooklyn 


N. 


Y. 


223 West Street 


New 


York 


N. 


Y. 


27 Columbus Avenue 


Spr 


Lng Valley 


N. 


Y. 


252 P 


enasylvania Ave. Brooklyn 


N. 


Y. 


3 E. 


14th St. 


New 


York 


N. 


Y. 


43 W. 


16th St. 


New 


York 


N. 


Y. 


106 I 


:'. 19th St. 


New 


York 


N. 


Y. 


1193 


Broadway 


New 


York 


N. 


Y. 


20 E. 


30th St. 


New 


York 


N. 


Y. 


141 S 


. Main St. 


Phi: 


LI ips burg- 


N. 


J. 


37-3E 


i 69th St. 


Woods ide 


L. 


I. 


126 n 


'.' 46th St. 


New 


York 


N. 


Y. 


10 II. 


Washington St 


Bos' 


ton 


Mass. 






Manville 


N. 


J. 


36 E. 


10th St. 


New 


York 


K. 


Y. 


289 B 


apperhan Ave. 


Yonkers 


N. 


Y. 


149 Ashford St. 


Bro. 


:klyn 


N. 


Y. 


2047 


E. 4th St. 


Brooklyn 


N. 


Y. 


34 Myrtle Avenue 


Sor, 


. Valley 


N. 


Y. 


119 li 


'. 23rd St. 


New 


York 


N. 


Y. 


98 Bleecker St. 


New 


York 


N. 


Y. 


1082 Broad St. 


Newark 


N. 


J. 


29 S. 


10th St. 


New 


York 


N. 


Y. 


35 W. 


24th St. 


New York 


N. 


Y. 



9811 



CONTRACTORS 



-157- 



NAME 

Superb Leather Goods Co. 
Superior Handbag Company 
H. Supnick 

Teddy Maiden Handbag Co., 

Samuel Teitelbaum 

The . Three Mountaineers 

Tip Top Handbag, Inc. 

Tivoli Handbag 

M. Triesti 

Trio Leather Goods Co, 



ADDRESS 

1613 E. K.Y. Ave 
120 f, 30th St. 
34 W. 27th St. 

34 Wall St. 
48 W. 25th St. 

28 W. 27th St. 
1523 E. 172nd St. 
15 W. 24th St. 
36 E. 10th St. 



CITY 

Brooklyn 

Hew York 
Hew York 

Horwalk 
Hew York 
Ashaville 
Hew York 
Hew Y'ork 
Hew York 
Hew York 



STATE 



H. 


Y. 


N. 


Y. 


H. 


Y. 


Co 


tin. 


H. 


Y. 


H. 


C. 


H. 


Y/ 


H. 


Y. 


H. 


Y. 


N. 


Y. 



Upright Leather Goods Co. 



115 W. 23rd St. 



Hew York 



N. Y. 



Vienna Bag Company 
Martina Vayroux 
Joe Vilaseca 



34 W. 46th St. 

137 Pine St. 

502 '.v. 147 th St. 



Hew York H. Y. 
S. Plainfield IT. J. 
Hew York H. Y. 



Warschauer Hovelty Co. 
Wonder Bag Company 
M. Zaro 
Z. Zwillenberg 



10 W. 33rd St. 
54 E. 11th St. 
118 E. 28th St. 
110 W. 27th St. 



Hew York 
Hew York 
Hew York 
Hew York 



H. Y. 

H. Y. 

H. Y. 

H. Y. 



9811 



■is: 



xgi si t a 

News Bulletins issued by the Code Authority 



9811 



-159* 

EXHIBIT "C" 
CODE AUTHORITY 
LADIES ' HAITBAG- INDUSTRY 
347 Fifth Avenue 

New York 

October 23, 1934 



I I EH BULLETIN 

Tiie News Bulletin is being issued by the Code Authority of the 

Ladies' Handbag Industry to keep al members of the industry 

posted and up-to-date on IGA neus, such as official rulings, 

interpretations, ets. In addition, contributions from members 

of the industry are welcomed and will be given the widest publicity, 

if of general interest. Your name wi 11 be withheld if you so request. 

Use the columns of the NEWS BULLETIN to ash questions, discuss, 

criticize or suggest. The staff of the Code Authority is always 

at your service, and a cordial invitation is extended to all members 

o." the industry to stop in and get acquainted. 

* * * 

TRADE PRACTICE COI.IPLAIFTS COi.lIITTEE : The Trade Practice Complaints Comm- 
ittee appointed by the Code Authority has been approved by the Administra- 
tor, and is now ready to function. A trade practice cormlaint refers to 
a complaint alleging violation of any provision of a code other than the 
labor provisions. Complaints b r members of the industry against other 
members of the industry or by any ~oerson against any member of the indus- 
try for violation of any of the fair trade practice rules of the code, 
may be filed with the Code Authority. In all cases, where the complainant 
states that he does not wish his name to be revealed, his wishes must be 
respected. Under separate cover there is being mailed a complete outline 
of the functions and workings' of the Trade Practice Complaints Committee. 

ADVERTISING- EXPENSES : A member Requested a. ruling on the following 
situation: "¥e would like to find out exactly what course of action 
to follow in regard to inserting pn advertisement in the Christmas 
Catalog sponsored by a resident buying office. This advertising 
is to be paid for by us directly to an advertising service company. 
This concern handles the entire physical make-up of the catalog for 
the resident buying office. The sum that we are to pay them is to 
cover only our part of the cost of the compostition, art work 



9811 



-150- 

photographs and engravings necessary to illustrate our merchandise." 

The ruling of the Code Authority follows: 

"Since the above office is a buver of your product, and also because 
they represent retailers who buy your product directly or indirectly, 
it would be considered a violation of the Code if you we^e to contri- 
bute or pay for any advertising sponsored by this resident buying office, 
or their appointed advertising agency. " 

ADVERT IS TIG : In the past it has been customary for printers to solicit 
manufacturers for the purpose of obtaining advertising for appropriations 
or allowances for the printing of a holiday catalog for retailers in which 
the goods of the manufacturer are offered for sale at retail thru the 
medium of the retailers' catalog. This form of advertising definitely 
comes under Section 1? of Article VIII of the Code of Pair Competition, 
and:. the payment for such advertising by a manufacturer would be con- 
sidered a violation of the Code. 



RETU?.i\ T S : The following letter addressed to a member of the industry, 
is of considerable interest and shears the attitude of the N3A in support 
of our Code provisions: 

"Your letter of October 12 addressed to Mr. Richberg, in which you cite 
the refusal of a handbag manufacturer to accept the. return of faulty 
merchandise with the inference that the code prohibits it, has been re- 
ferred to me for attention and reply. Article VIII, Section 13 of the 
Code reads as follows: 

•Mo member of the industry shall accept the return of any 
merchandise shipped to a purchaser, nor allow credit there- 
for, nor exchange merchandise, after the merchandise has 
been in the possession of the purchaser for more than seven 
days, where the agreement of sale has been fuliy performed 
by such member. ' 

This provision was included in the Code to remedy an abuse of the re- 
turn goods practice which had grown in the industry. "iany merchants 
had formed the habit of le? ving merchandise on their shelves or in 
their warehouses, and --'hen the season was over and they found the mer- 
chandise did not have '> ready sale they returned it, asking the manu- 
facturer for credit. Likewise, many merchants Permitted the merchandise 
to become damaged in storage,- and after weeks and even months they asked 
the manufacturer to accept the return of merchandise which had become 
damaged through no fault 'of the manufacturer. It was felt in approving 
the code that seven days was sufficient time for a merchant to scrutinize 
the merchandise, a.nd that by putting this limit on its return an unfair 
trade practice would be eliminated. 

There is also a provision in Article VIII, Section 4 of the Code which 
prohibits a. member of the industry from branding or marking or -packing 
any goods in any manner which is intended to or does mislead purchasers 

9811 



~151-» 

with respect to the brand, grade, duality, ouantity, origin, 
etc., and if the merchandise of a manufacturer is found to he 
common split leather when it has oeen branded or sold of 
leather of a higher grade, you are not only privileged to 
return it but it is your duty to report the firm manufactur- 
ing it to the Code Authority as 8 violator of the Code. Aside 
from this Protection, it was not intended in approving the 
Code that it would preclude the return of merchandise which 
was faulty in manufacture, even though the seven day period 
had elapsed. 

I believe you will find the Code Authority of the Ladies' 
Handbag Code very sympathetic to your problem, and they will 
no doubt suggest the proper action for you to take." 

(signed) Leigh E. Ore 
Assistant Deputy Administrator 

TF" "S : It is a violation of the Code to sell on terms in 
excess of ?/l<"> eom. jTirst of the nontli d* ting for goods 
shipped after the twenty-fifth of the preceding month is in 
excess of 3/l0 eom. If you grant first of the month dating, 
you are violating the Code for the Ladies' Handbag Industry. 



ASSESSMENTS: Your attention is called to the fact that 
sales assessments are now cue ^no payable for September. In 
accordance with MEA ruling, assessments are based on sales 
from March 25, 1934, the effective date of the code. If you 
have not already done so, please include sales figures from 
March 26-March 71 with your next label order. 



LA3ELS : Since July 2, 1934 the date 3RA labels became ef- 
fective in the industry a grand total of 13,841,800 labels 
have been issued up to and including October 19, 1934. 

Regular Labels 13,059,000 
Stock on Band 538,000 

Retailers 244,800 



LABEL DISPOSITION R"C0RDS: The SUA label signifies that all 
ladies' handbags, pocketbooks or purser bearing such labels 
are manufactured, under Code conditions as to wages, hours, 
trade practices, etc. The entire purpose of the NRA label 
is defeated if no control is maintained. The La.bel Disposi- 
tion Record is designee so that you, the legitimate manu- 
facturer, can be assured that the "chiseler" will not obtain 
labels without complying with all provisions of the Code. 

9811 



-162- 

It is inroerative that these records "be submitted as the Label 
Division cannot issue labels unless the instructions on the 
Label Order are fully complied with. Unless Label Disposi- 
tion Secords completely filled out accompany every label 
order, the Code Authority cannot effectively -nrotect your in- 
terests.. 



COMPLIANCE DIVISION - STATISTICS (September 30, 1934) 

Ivumber of Investigations Made 567 

; r on-Conroliance Cases Pending 58 

ITon-Comoliance Cases Closed 105 

Restitution 

Number of firms .- 43 

ITumber of individual Employees 814 

Total Amount ^aid -11,393.53 
Arroroximate amount send- 
ing ^,000.00 
'umber of Manufacturers 325 

Number of Contractors 173 

Approximate Kunber of Torkers 

Enrol oyed in the T ndustry US, 800 



DQU13LF, S TT I P T: Requests have come from members requesting 
permission to enrol oy a double shift of workers. The Code 
Authority has ruled that in order to work two shifts, it 
involves the operation of a factory from six a.m. to twelve 
midnight. This is not a mechanized industry in which a 
double shift relies chiefly on the operation of machinery. 
It is almost entirely table work, and reouires close am- 
plication of the worker to his work, and when performed under 
artificial light, it involves a ohysical strain especially 
on the eyes of the workers. A double shift affords an op- 
portunity to workers who may work during the daytime in 
one factory to aualify for the night shift in another, in 
violation of the Code. The Code Authority feels that manu- 
facturers should be able to make -nrovision to increase 
their -oroduction during the eight hours nermitted by the 
Code thru the addition of space and machinery. 



PAYROLL PFP0P.T5: Payrol] P^oort Sheets have been furnished 
to all manufacturers in the industry. Section 8 (c) of the 
Code, authorized the Code Authority to obtain information 
and reoorts re^ui^ed for administration of the Code. The 
Ladies' Pandbag Industry has never had true vital statistics 
and failure to submit payroll reoorts severely handicaps the 
Code Authority in its ende-'-'vor to maintain uo-to-date and 
accurate statistics of the Tndustry. Your earnest cooperation 
is reouested. 

* * * 

9811 



-163- 

CONTRACTORS: Before giving out work to a contractor, make certain 
that he has signed the Contractors' Compliance Form, as no labels 
will he issued to be used by contractors who have not signed this 
form. 



* * * 

CONTRACTORS' AGREEMENT : The National Industrial Recovery Board has 
approved a standard form of "Contractors' Agreement" between members 
of the ladies' handbag industry and contractors whereby contractors 
signing the agreement pledge themselves to "comply with all provis- 
ions of the code of fair competition" for the industry. In signing 
the approved agreement, contractors are pledged to sign a "Contractors' 
Compliance Form" issued by the industry' s Code Authority. (Copies of 
this agreement will be available very shortly.) 

* * * 

TIME BOOKS: The Compliance Division requires all payroll 
records to be kept in a separate time book, and all entries 
to be made in ink. 

TRADE PRACTICE COMPLAINTS COLl/IITTE E: The Trade Practice Complaints 
Committee is empowered to hear all complaints arising out of vio- 
lations-of the trade practice rules of the Code of Fair Competition 
for the Ladies' Handbag Industry. In order that each member of the 
industry may familiarize himself with the duties and functions of 
this committee, we are sending herewith a copy of the rales govern- 
ing the procedure of the Trade Practice Complaints Committee. 

* * * 

HANDBAG FRAME DESIGN REGISTRA TION: The following notice has been re- 
ceived from the Code Authority'- of the Handbag Frame Manufacturing 
Industry: 

"TTe take pleasure in announcing the designation of 
the Design Registration Bureau, operated under the 
auspices of the Rhode Island School of Design and 
located at Providence, R.I., as the impartial and 
disinterested agency to be used by members of this 
Industry for the registration of original frame 
designs. 

The Code Authority has designated this Bureau 
pursuant to the provisions of Article IX of the 
Supplementary Code of Fair Competition for this 
Industry, and this designation has received the 
approval of the National Recover"/ Administration. 

Registration of original frame designs commenced 
on Monday, October 22, 1934. Protection of registered 
designs expires sis months from the date of registra- 
tion.' 

9811 



-164- 

We believe that design registration in this Industry will work 
to the distinct advantage of your members as well as our own, 
and we earnestly solicit your full cooperation in the preven- 
tion of the piracy of registered designs." 

The Code Directors will he glad to answer any questions regarding 
the effect of such registration on the handbag industry. 

* * * 

The Code Directors can help you in cases when — 

Your customers return goods after seven days. 

Your customers pay on terms other than the Code terms, 

3/10 eom. 
Your customers insist that you pay for their advertising. 
When you are asked to give anything of value for the purpose 
of influencing or rewarding the action of any employee, 
CONSULT THE CODE DIRECTORS 

* * * 

DISTRESSED MERCHANDISE ; We desire to call your attention to Trade 
Practice Rule 15, Article VIII. 

"No member of the industry shall dispose of distressed mer- 
chandise except upon prior notice to the Code Authority, along 
with such information as the Code Authority and the Administra- 
tor may prescribe. General fall competitive items shall not 
be sold as distressed merchandise prior to December 26 , general 
spring competitive items shall not be sold as distressed mer- 
chandise prior to Mother's Day, and general summer competitive 
items shall not be sold as distressed merchandise prior to 
July 4. Subject to review by the Administrator, the Code Au- 
thority may permit the sale of merchandise at periods other 
than those herein established." 

This provision will be strictly enforced. 

Temptation is greatest at this time of the Year to manufacture addi- 
tional quantities to take care of "last minute Christmas orders". 
These additional quantities frequently prove to be the sponge that 
absorbs all the profits of the season. 

Try to make your percentage of close-outs at the end of this season 
the smallest you have ever had, not forgetting that goods manufactured 
to sell at $21.35, if sold for $15.00 a dozen, means a drop of 32|$e. 
Can you afford to take it? 



HOMEWORK ; There will be a hearing in Washington on Tuesday, November 
20, 1934 at 10:00 A.M. Room 128, Willard Hotel, to consider the 
proposed interpretation and amendment proposal of the Pleating, 
Stitching and Bonnaz and Hand Embroidery Industry. 

9811 



-155- 

In accordance with the interpretation proposed "by the above industry, 
homework on hand-beading, hand-crocheting and handsajfo'bnnL&ery '.'ill- 
be prohibited. Since this change might seriously affect your inir 
tsres^ you may wish to attend this hearing. If you desire to speak 
against the proposal, please let us know, so that we may register 
your name with the Administrator in charge of the hearing. If you 
cannot be present in person, write or telegraph to Mr. I.i. D. Vincent, 
Acting Deputy Administrator in charge, expressing your views. 

* * * 

Members of the industry are reminded that the workers in 
their office, stock room and shipping department come under 
the wage and hour provisions of the Code, the same as factory 
workers. 

Article III, Section 2, provides . . . "Ho person employed 
in shipping, clerical, or office work, unless he is employed 
in a managerial or executive capacity and earns not less than 
thirty-five dollars ($35.00) per week, shall be permitted to 
work in excess of forty (40) hours per week averaged over any 
one (l) month period." 

COMPLIANCE DIVISIOH - STATISTICS (October 31, 1934) 

Number of Investigations Made 807 

Non-Compliance Cases Pending 49 

Non-Compliance Cases Closed 130 

Restitution 

Number of firms 47 

Number of Individual Employees 901 

Total Amount Paid $12,024.22 
Approximate amount 

pending $10,200.00 

Number of Manufacturers 325 

Number of Contractors 173 
Approximate Number of Workers 

Employed in the Industry 15,300 

* * * 

SPECIAL SALES : A certain retailer now in the market is seeking to 
obtain a special concession of a single quantity of bags, so he put 
it to a manufacturer in this manner: 

"All I want is six dozen of your regular new fall goods at a special 
price for a. sale. " 

Aside from the fact that it definitely ruins the sale of your new 
fall styles in that particular city or cities, it creates a resent- 
ment against you by all other manufacturers who may be forced to 
follow you and accede to the demands of this buyer. It is an old 



9811 



-166- 

trick, and it is obvious that by getting si;: dozen bags at a special 
price from ten or more manufacturers, this buyer has succeeded in 
making his full purchases from 20$ to 30$ less than the regular 
prices. Do not lend yourself to this old and worn' out method of 
chiseling. 

There are five good reasons why you should not: 

You are creating unfair competition for your customers who 
in good faith have bought the same goods from you at regular 
prices. 

You are destroying your complete line in \7hich you made a sub- 
stantial investment. 

A "special sale" of only six dozen bags is just as quickly 
knc~u- to other buyers as it is to other manufacturers. 

You have destroyed the confidence in the very buyer to whom 
you have granted this "special buy". The natural inference is 
t .oi if you did it for him. you would do it for others. 
Therefore, your line is nc-c desirable at regular prices for re- 
gular selling. 

The most important reason is that you did not allow for such 
"special buys" in figuring the cost of these bags. 

"PROTECT YOUR PROFITS" 

IMPORTED MERCHANDISE ; The following letter was received from the 
N.R.A. : 

"SUBJECT: Status of Relationship between Ladies' 
Handbag Code and Importing Trade Code. 

A question of jurisdiction, assessment, etc., has arisen between 
the two above mentioned codes. There are in this picture three dis- 
tinct groups, namely: (l) the strictly manufacturer of ladies' hand- 
bags; (2) the manufacturer who also imports ladies' handbags; (3) the 
strictly importer of ladies' handbags. 

The first shall operate entirely under the provisions of the 
code for the ladies' handbag industry and shall pay to this industry 
all assessments. The second class shall operate under the code govern- 
ing the major part of their business, for example: if a manufacturer 
does $100,000 worth of business, sixty per cent of which he manufactures 
himself, importing the other forty per cent, he shall be governed by 
the code for the ladies' handbag industry and shall pay assessments 
to said Code Authority on the $10Q.,000 figure. He is not subject to 
ary assessment of the Importing Trade Code Authority, because such 
Crrjfj Authority does not have an exemption under X-36. TThere a manu- 
facturer of ladies' handbags imports some of the integral parts of the 
complete bag and is, we might say, primarily an "assembler", he is 
subject to the Ladies' Handbag Code entirely. The third is an importer, 
strictly, and is subject only to the code for the Importing Trade." 

9811 



-167- 

PAYROLL REPORT S: Payroll Report Sheets have been furnished to all 
manufacturers in the industry. Section 8 (c) of the Code, authorized 
the Code Authority to obtain information and reports required for ad- 
ministration of the Code. The Ladies' Handbag Industry has never had 
true vital statistics and failure to submit payroll reports severely 
handicaps the Code Authority in its endeavor to maintain up-to-date 
and accurate statistics of the Industry. Your earnest cooperation is 
requested. 

* * * 

TERMS : It is a violation of the Code to sell on terms in excess of 
3/10 eom. First of the month dating for goods shipped after the 
twenty-fifth of the previous month is in excess of 3/10 eom. If you 
grant first of the month dating you are violating the Code for the 
Ladies' Handbag Industry. 

* * * 

ASSESSMENTS : Your attention is called to the fact that sales assess- 
ments are now due and payable for October. In accordance with NRA 
ruling, assessments are based on sales from March 2S, 1934, the eff- 
ective date of the code. If you have not already done so, please 
include sales figures from March 26-March 31 with your next label 
order. "-• 

LABEL SALES 



JULY 
AUGUST 
SEPTEMBER 
OCTOBER 
GRAND TOTAL 



T OTAL 
2, 154, 000 
3.52S, 500 
3,487,000 
4.045 ,000 
13,215,500 



WEEKLY AVERAGE 
512, 857 
741,109 
940,806 
879,348 



DAILY AVERAGE 
102,571 
148,202 
188,161 
175,869 



GEOGRAPHICAL DISTRIBUTION 
(AS OF SEPTEMBER 30, 1934) 



LOCATION 



LABELS ISSUED 



PER CENT 



New England 

Middle Atlantic (not including i.TC) 

New York City 

Middle West 

South 

Pacific Coast 



2,959,500 

3,756,200 

3,594,300 

436,875 

129,000 

66.000 

10,941,875 



27.0 
34.4 
32.8 

4.0 
1.2 

._6_ 

100.0 



* * * 



THE LABEL DISPOSITION RECORD IS ADVANTAGEOU S 
TO THE INDUSTRY 

There are many manufacturers who have already adopted the Label Dis- 

9811 



-168- 

position Record as one of their own records because of its value to 
them as a statistical record of production . Some of these manufactur- 
ers never had" such a record before, never knew what their production 
actually was, and had no means of comparing their present production 
with that of any past period* 

Some manufacturers depended upon the cutting foreman to record the 
production on some scrap of paper or other informal record.. Produc- 
tion figures thus depended upon the foreman's accuracy, his memory, 
his arithmetic, or his veracity. Wow that there must he a label for 
each handbag, these manufacturers have accurate figures to which they 
can refer at any time. Q 

Some manufacturers use the Label Disposition Record as a physical 
inventory control over their slip; and as a method of preventing pay- 
roll padding . The shop is charged with the quantity cut,' as per the 
Label Disposition Record, and credited with the quantity completed 
as per the payroll sheets or actual charges to the finished goods 
stockroom. The difference is the inventory of goods in -orocess and 
this is checked weekly or monthly by a physical count. The inventory 
of goods in process is also used by some manufacturers on their month- 
ly financial statement to give them a more accurate picture of their 
operations. 

Many manufacturers who previously had inadequate cost records are now 
determining their labor costs- by dividing the weekly apyroll amounts 
by the production per Label Disposition Record. TThes® are but a few 
of the advantages. No doubt there are many more. 



9811 



-169** 

EXHIBIT "C" 

CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

347 Fifth Avenue 
New York 



VOL. II. No. 3 - NEWS BULLETIN DECEMBER 5. 1934 

MR. RICHBERG'S VIEWS ON A PERMANENT N.R.A. PROGRAM : "In the first 
place, I believe that there is a demonstrated soundness in the fixing of 
minimum wages and maximum hours for each trade and industry for the 
purpose of preventing the worst forms of unfair competition in the 
overworking and underpaying of emrloyees. If these requirements are 
fixed by common agreement, if they are flexible enough to fit actual 
conditions, if they are not the last word, but left subject to improve- 
ment by collective bargaining, they should protect both employers and 
employees and advance the public interest. In the same way by ccmmon 
consent the intolerable evil of child labor should be outlawed from trade 
and industry. 

"In the second place, admittedly dishonest business practices should 
be prescribed. But in the twilight zone between dishonesty and legitimate 
competition* trade and industry should seek first to establish an 
accepted standard of unfairness before before writing mandatory require- 
ments in a code. Enforcement must fail where there is no general agree- 
ment that a law should be enforced* We must wait in patience for the 
development of a custom that has attained almost the force of law before 
we ask to write it into law and to comnel dissenters to obey it. 

"In the third place, statistical information, accurate and compre- 
hensive, is necessary for economic security in an industrial civiliza- 
tion. Business should not grope its way ahead in fogs of uncertainty. 
It is in the common interest that exact reports of production, prices, 
wages, employment, and such fundamental knowledge of economic conditions, 
should be available to all who have the desire and intelligence to chart 
the course of commerce and finance according to the ever shifting balance 
of supply and demand. 

"Finally, to what extent should we rely upon and insure the freedom 
of agreement among organizations of enrol oyer s and employet s to promote 
their separate and common economic interests." 



The Code Authority mast insist that your payroll reperts, and label 
disposition records are filled out and returned to us not later than the 
tenth day of each month. If you do your part, the statistics for the 
industry at the end of the fiscal year will be invaluable for every 
member of the industry. 



LABELS : In order to facilitate the examination of bags for label 
9811 



-170- 



requirements, we have been requested by large retail distributors to 
instruct the manufacturers to place the labels in a uniform position in 
the bag. The Code Authority has ruled that in every case possible, the 
label shall be inserted in the left-hand side of the mirror pocket with 
the numerals showing. 



FALSE ADVERTISING : Some manufacturers have been manufacturing 
bags of seal split and inserting cards: in eacn bag stating that they 
are "real seal" or "genuine seal." A few large retailers have recently 
inserted advertisements on these bags also calling them "real seal" or' 
"genuine seal". The Code Authority has stopped this practice as it is 
a violation of Section 4, Article VIII of the Code, and also, as it is 
prohibited by a ruling of the Federal Trade Commission on a similar 
case. 

On February 2, 1934, the Federal Trade Commission ruled "That in 
connection with the sale, offering for sale, or distribution in inter- 
state commerce and the District qf Columbia of handbags, suit cases 
and other luggage or other products made from the under layers of 
sealskin known as "Split Seal", cease and desist from designating and 
describing the same as "Seal" or "Genuine Seal" unless the word "Seal" 
is modified by the word "split" in letters equally conspicuous or other 
expression clearly and conspicuously designating that the material is 
an under layer of sealskin." The Code Authority will strict.lv enforce 
this provision of the code. 



TERMS ; It is a violation of the Code to sell on terms in excess of 
3/10 eom. First of the month dating for goods shipped after the twenty- 
fifth of the previous month is in excess of 3/10 eom. If you grant 
first of the month dating you are violating the Code for the Ladies' 
Handbag Industrv. 

FURTHER ADVANTAGES OF LABEL DISPOSITION RECORD : Where contractors 
are used, the number of handbags in work at contractors is easily 
ascertained by some manufacturers thru the use of the Label Disposition 
Record. This is done by charging the contractors with the production, 
per Label Disposition ecord, and crediting them with the finished goods 
per receiving record or purchase book. The difference represents hand- 
Dags in work at contractors and the fluctuation of this figure is 
carefully watched. This in-process inventory at contractors is similarly 
used on the monthly financial statements. This control may also be 
valuable in preventing padding of bills by contractors. 

Some manufacturers feel that they now have a better control of 
overshipments and under shipments by contractors thru the numerical 
advantage afforded, by the Label Disposition Record. 

The Label Disposition :R.ecprd has also been found to be valuable 
because it gives the manufacturer a record to which he can refer, either 
to refresh his memory, or to detect clerical errors such as forgetting 
to charge a. contractor with goods. 

9811 * * * 



-171- 

COMPLIANCE DIVISION - STATISTICS (November | 30, 1934) 
Investigations: 



Number Previously Reported 
Number Made During November 

Number Non-Compliance C ase s Pending 
Number Closed During November 



Total 



807 
274 

72 
90 



1081 



Restitution: 



Number of Firms 

Number of Individual Employees 

Total Amount Paid $13,347.39 

Approximate Amount Pending . $10,000,00 



53 
934 



REGULAR LABEL SALES 



TOTAL 



JUNE 
JULY 
AUGUST- 
SEPTEMBER 
OCTOBER 
NOVEMBER 
TOTAL REGULAR LABELS 



1,220,000 
2.154,000 
3,529,500 
3,487,000 
4,045,000 
4.510,000 
18,745,000 



WEEKLY AVERAGE 



426,571 
512,857 



879,348 
1,023,080 



TOTAL STICKER LABELS (Mfrs. and Retailers)... 783,800 
GRAND TOTAL . 19,528,800 



GEOGRAPHICAL DISTRIBUTION 
(as of OCTOBER 31, 1934) 
Manufacturers Only 



DAILY 
AVERAGE 



85,714 
102,571 



741,109 146,202 
940,806 188,161 
175,869 
204,616 



LOCATION 

New England 

Middle Atlantic (not including NYC) 

New ^ork City 

Middle West 

South 

Pacific Coast 



LABELS ISSUED 

3,856,125 

5,273,200 

4,930,300 

624,375 

215,000 

99,500 

14,989,500 



PERCENT 



25, 


,7 


35. 


,1 


32, 


,9 


4. 


,2 


1- 


,4 


1 


7 



100.0 



9811 



-172- 

CHILD LABOR : One of the most important provisions in the code is 
the prohibition against employmentof minors below the age of sixteen. 
The Code Authority takes pride in the fact that the industry is unusually 
free from violations of this character and the Administration has com- 
mented upon this favorably. 



TIME CARDS : Time cards must not be destroyed. They must be avail- 
able for inspection by the Code Authority investigators. Failure to 
preserve and submit time cards will be considered evidence of violation 
of the Code provisions regarding hours and wages. 



MANUFACTURERS OF BRAIDED BAGS : Under Executive Order of June 6, 1934, 
homework on braided bags was strictly prohibited. The Compliance Division 
has received a number of complaints that this order is being violated, and 
will take the necessary steps to eliminate such violations. 



CONTRAC TORS AGREEMENTS t Pursuant to Section 12 of Article V of the 
Code for the Ladies' Handbag Industry, a' form of Contractor's Agreement 
has been approved by the Administration, copy of which is enclosed 
herewith. 

This agreement is to be used whenever work is given out on a con- 
tract basis. Additional copies of this agreement are available on request. 



ASSESSMENTS : Your attention is called to the fact that sales 
assessments are now due and payable for 'November. .In accordance with 
NRA ruling, assessments are based on sales from March 26,1934, the 
effective date of the code. If you have not already done so, please 
include sales figures from March 26 - March 31 with your next label order. 



Tell the Code Authority your problems. If it is an industry problem, 
it cannot be yoars alone, it must be common to the entire industry. Why 
not tell the Code Authority and let them solve it for the industry. Use 
the columns of the NEKS BULLETIN as a forum for discussion. Your sugges- 
tions or criticisms on any matters pertaining to the industry will be 
welcome. r 



Additional copies of this NEWS BULLETIN are available to members of 
the industry for distribution to their sales offices and other plants. 



9811 



-173- 

CODE AUTHORITY 

LAIIES'' HANDBAG INDUSTRY 

347 Fifth Avenue 
New iork 

-IB- 



SEASON'S VOL. II, No. 4 NEV.S BULLETIN DEC EMBER 21, 1934 

GREETINGS At this time of the year, it is customary to look "back and 
take stock of our accomplishments during the past twelve months. 
The Code for the Ladies' Handbag Industry was approved by the President on 
March 14, 1934, and went into effect twelve days later. In the language of 
the National Industrial Recovery Act, the policy was declared to be "to 
provide' for the general welfare by promoting the organization of industry 

for' the purpose of cooperative action among trade groups to eliminate 

unfair competitive practices to reduce and relieve unemployment 

and otherwise to rehabilitate industry and to conserve national resources." 

The Code has accomplished a great derl to change the basis of com- 
petition in the industry from that of underpaid labor and unregulated hours 
of work to that of competition based on style, quality and service. The 
Code has effected the elimination of child labor and the establishment of 
the minimum wage in all branches of the industry. A stronger feeling of 
confidence and security prevail in the industry, which reflects the improv- 
ed conditions already apparent, 

■'■t has been the endeavor of the Code Directors to administer the Cod e 
for the Ladies' Handbag Industry without fear or favor, without unnecessary 
severity or bureaucratic methods, but in a true spirit of justice and 
fairness to all, and with an earnest desire to be of the utmost service to 
the industry. 

The Cede Authority extends greetings and good wishes to all engaged 
in the industry who thru their cooperation, have made it possible for the 
Code Authority to accomplish such benefits as have come to the industry 
thru the administration of the Code, Your continued loyalty and support 
are necessary to bring added benefits during the year 1935. 

ADMINISTRATIVE ORDER NO. X-124 

Interpretation: Effect of temporary interruptions in work beyond 
control of employee as affecting maximum hours and computation of wages under 
various codes. 

Facts: Complaints have been received concerning practices of certain 

employers, subject to various codes, whereby the employer 
requires his employee to take time out without pay during the course of 
a work day for periods of inactivity due to breakdowns, delay, time spent 
waiting for materials or waiting for the loading or unloading of railroad 
cars or ether vehicles of transportation, and interruptions in acticity 
due to other causes. 

Question: Under the maximum hour and minimum wage provisions in codes, 

may an employer properly reouire an employee to take time out 
for such interruptions and not compute such time in determining maximum 
hours of labor and the wages of such employee? 
9811 



-174- 

Interpretation: Time furing which an employee is inactive "by reason of 

interruptions in his work beyond his control may not 
be construed as time not worked, nor excluded in computing his hours of 
labor and wages. The term "interruptions" includes, but without limita- 
tion, the specific instances hereinabove set forth under "Facts" whenever 
the imminence of resumption of work requires the employee's presence at 
the place of employment. Such requirement is to" be presumed in the 
absence of adequate prior notice ( from the employer that the employee is 

1 free to leave his place of employment if he desires. An emrloyer may 
not, however, by notifying an emplo5 r ee that he is free to leave for an 
interval too brief -reasonably to be considered a temporary layoff, thus 
avoid computing such period as .time worked. Nothing herein contained, 
however, shall be construed to modify or affect in any way bona fide, 
voluntary and mutual agreements concerning the subject matter hereof, 
arrived at by employers and employees, when the same are not in conflict 

•with the maximum hour and minimum wage provisions of the code applicable 
to such parties. 

NATIONAL INDUSTRIAL RECOVERY BOARD 
(Signed) «. A. Harriman 

Administrative Officer 



NEV CONSUMER EMBLEn AVAILABLE : In response to numberless requests 
for a 1934 Consumer's Emblem to symbolize- cooperation with NBA codes, an 
attractive small sticker has been prepared for display in homes, on 
automooile windows where permissible, etc. These emblems may be obtained 
by writing or telephoning to the Local NBA Committee in your town or city. 
Last year, 60 million consumers signed pledges of cooperation witn the 
President's Beemployment Agreement. The 1934 pledge re-affirms allegiance 
to the Code Blue Eagle as follows: "In the national effort to bring 
security to all, I will encourage and patronize those business establish- 
ments in which the Blue Eagle of NBA Codes is displayed." 

REGULAR LABEL SALES 

GEOGRAPHICAL DISTRIBUTION 
(as of NOVEMBER 30, 1934) 

Manufacturers Only 

LOCATION LABELS ISSUED PERCENT 

New England . 4,569,125 23.8 

Middle Atlantic (not 

including. NYC) 6,792,700 

New York City 6,720,300 

Middle West , 800,875 ... 

South 269,000 

Facific Coast 117.500 

g g 11 ' - 19,309,500 . •. . 10.0.0 



35. 


2'. 


34. 


,8 


4. 


,1 


1. 


5 


4 


,6 



-175- 



SUMMARY SHOWING- PERCENTAGES BY MONTHS 





AUG. 31 


SEPT. 30 


OCT. 31 


NOV. 30 


New England 


27.5 


27,0 


£5.7 


23.8 


Middle Atlantic 


32.0 


34.4 


35.1 


35.2 


New York Citv 


34.4 


32.8 


32.9 


34.8 


Middle Vest 


3.9 


4.0 


4.2 


4.1 


South 


1.6 


1.2 


1.4 


1.5 


Pacific Coast 


.6 


.6 


.7 


.6 



CENSUS OF MANUFACTURERS : The U. S. Department of Commerce, Bureau 
of the Census, has issued census figures obtained in 1933 for the manu- 
facture of pocketbooks, pur set; and card cases. 

Statistics for 1933, with comparative figures for earlier years, 
are given in the following tables. All figures for 1933 are preliminary 
and subject to revision. 

S ummary for the Industry: 1933, 1931, and 1929 



1933 



1931 



1929 



Number of establishments 
Cost of materials, fuel, and 
purchased electrin energy- 
Value of products 
Value added by manufacture 



216 

$15,298,920 
$28,299,004 
$13,000,084 



260 

$22,600,817 
$43,147,053 
$20,546,236 



290 

$35,351,605 
$68,627,515 
$33,275,910 



ADVERTI S ING" EXPENSES : It is a violation oi Trade Practice Rule 12 of 
Article VIII of the Code of Fair Corn-petition tor the Ladies' Handbag 
Industry if you pay to circularize your bags thr trie medium of any large 
buying organization. The investigators are instructed particularly tc look 
for such violations. 



BLUE EAGLE : The use of the Blue i^agle Insignia on any cards or labels 
inserted in bags is absolutely illegal unless it is the official label cf 
the Code Authority of the Ladies' Handbag Industry. 



MISBRANDING : The Tanr-ers' Council and the Code Authority of the 
Leather Industry are cooperating with the Ladies' Handbag Code Authority 
to step all misbranding of the kinds- and qualities of leather. 

The Federal Trade Commission has ruled that cowhide splits cannot be 
labeled "genuine cowhide" cr "real cowhide". The Code Authority will defi- 
nitely restrain any member of the industry from branding any split leather 
genuine or real thru the use of labels or by inserting into the bag a printed 

ticket. 
9811 



-175- 

IF FATEFT LEATHER COMES : Do not forget that cold wee.taer and crack- 
ing patent leather are almost synonymous. Frotect yourBelf "by standing 
squarely behind the seven day return provision in the Code, and make 
doubly sure by inserting cards in your bags that "patent leather" is not 
guaranteed and cannot be returned because of cracking. 



HOmEWORK : The Code Authority has approved a plan for the control of 
homework and the abolition of Child labor. The plan requires the regis- 
tration with the Code Authority of all homeworkers on hand-beading and 
crochet-beading. The Code Authority .will set all piece work prices to be 
paid homeworkers on hand-beading and crochet-beading. All other homework 
operations, such as finishing of bags or leather braiding is strictly 
prohibited. 



FREE GOODS : The Code Authority has ruled that the giving oi free 
goods such as initials or other articles not attacned to or a part of such 
bags is a violation of a trade practice rule. 



RETURNS : Members of the industry are reminded that for various reasons, 
this season of the year brings forth unjustified returns of merchandise. 
Section 13 of Article VIII reads: : 

"No member of the industry shall accept the return of any merchandise 
shinned to a purchaser, nor allow credit therefor, nor exchange 
merchandise, after the merchandise has been in the possession of the 
purchaser for more than seven davs, where the agreement of sale has 
been fully performr-d by., such' member. '•' 

This rule is designed to protect you against this evil Why not 

take advantage of it? ^ 



9811 



-177- 
Exhibit "C" 

CODE AUTHORITY 
LADIES' EA1TDBAG IITDUSTEY 
347 Fifth Avenue 
jJew York 



VOL. Ill Ho. 1 HEWS 3P LEBTET JA.7 UARY 35. 1935 

SUBJECT: Ruling on Ladies' Handbags 



In -accordance with your recent inquiry, the recommendations which 
I made at the hearing conducted .a January 9, 1935, relative to 
the proposed amendments to the Code of the Ladies' Handbag Industry 
may be restated somewhat as follows! 

First, a general rest' tenant would 
emphasize that the codification of any 
industry should be accomplished so that 
the definition of the product be expressed 
in terms of generic classification and not 
in terms of "for the purpose used" or "to 
whom sold" , jr "by whom carried" or some 
such similar qualification limiting the 
product. 

Second, on the basis of the above and 
from the data and exhibits presented for 
examination and which I reviewed, it is 
recommended that the definition include all 
items embraced by the generic classification 
o f ".the 1 p r o due t . " 

AH of the products exposed at the hearing were "handbags", 
and if the group classification should be broken down into 
parts depending upon the material used, it is obvious to all 
that ridiculous situations might be precipitated. 

(Signed) GEORGE S. BRADY 

Assistant Administrative Officer 



1934 EAGLES GOOD III 1935; The 5TIHB has announced 
that Blue Eagles for particular trades and industries 
marked "1934", as well as those originally issued 
under- the President's Reemployment Agreement, may be 
used in 1935. 



9811 



-178- 



EXEGUTIVE ORDER 
#6686 

PRESCRIBING A REGULATION PROHIBITING DISMISSAL OE EMPLOYEES 

EOR REPORTING ALLEGED 'VIOLATIONS OE CODES OE 

FAIR COMPETITION 



By virtue of end pursuant to the authority vested in me under 
Title I of the National Industrial Recovery Act of June 16, 1933 
(ch 90, Stat. 195), and in order to effectuate the purposes of 
said title, I hereby prescribe the following rule and regula- 
tion: 

No employer subject to a code of fair competition 
approved under said title shall dismiss or demote 
any employee for makirg a complaint or giving evi- 
dence with respect to an alleged violation of the 
provisions of nny code of fair competition approved 
under said title. 

All persons are hereby informed that section 10 (a) 
of the National Industrial Recovery Act prescribes 
a. fine not to exceed five hundred dollars ($500) or 
imprisonment not to exceed six (6) months, or both, 
for the violation of any rule or regulation prescribed 
under the authority of said section 10 (a). 



(Signed) PRANK' LIU D. ROOSEVELT 



THE WHITE HOUSE 

May 15, 1934. 



*************** ^** ***************■************::• * si:*** * **** * * •■:**** 



CONTRACTORS : This office must be notified immediately upon taking 
on any new contractors. Unless you agister your contractors you 
are not permitted to issue labels to them. 



RETURNS : Members of the industry are reminded that for various 
reasons, this season of the ye^.r brings unjustified returns of 
merchandise. Sectia 13 of Article VIII reads: 



9811 



-179- 



"No member of the industry shall accept the 
return of my merchandise shipped to a purchaser, 
nor allow credit therefor, nor exchange 
merchandise, after the merchandise has "been in 
the -possession of the purchaser for more than 
seven days, where the agreement of sale has 
"been fully performed "by such member." 

This rule is designed to protect you against this evil 
Why not talre advantage of it? 

REF?,i; r TED VOL. II - Ho. 4 
NEWS BULLETIN 



COMPLIANCE DIVISION -'.S TATISTICS (December 31, 1934) 
Investigations: 



Humbcr Previously Reported 
Number Made During November 

Total 

llumber Non-Compliance Cases Pending 
Number Closed During November 



1031 
326 



56 
49 



1407 



Restitution: 

Number of Firms 
Number of Individual Employees 
Total Amount Paid $13,891.14 
Total Amount Pending $12,640.10 



50 
1008 



LABEL DIVISION ( December 31, 1934) 

REGULAR LABEL SALES 

TOTAL WEEKLY AVERA GE 

JUNE 1 , 220 , 000 428 , G71 

JULY 2 , 154 ,000 512 , 857 

AUGUST 3,529,500 741,109 

SEPTEMBER 3,487,000 940,806 

OCTOBER 4,045,000 879,548 

NOVEMBER 4,310,000 1,023,080 

DECEMBER 2, 410,0 00 '■ 2,500 

Total 21,155,(500 

Total Sticher Label 

(Mfrs. and Retailers) 



. 800,000 
GRAND TOTAL 21 ,955,000 



DAILY AVERAGE 

85,714 
102 ,571 
148 ,202 
188,161 
175,369 
204,616 
IP , 50( 



9811 



-180- 



REGULAR LABEL SALES 

C- E , G R A P H I C A L D I S T B-.I B TJ T I N 
(as of December 31, 1934) 

Manufacturers Only 

LOCATION LABE LS ISSUE D PER CENT 

Sew England 5,095,625 23.5 
Middle Atlantic (not 

including NYC) 7,761,200 35.8 

New York City 7,557,800 34.8 

Middle lest 839,875 3.8 

South ■ • 333,000 1.5 

Pacific Coast 132,000 .6 

21,719-,500 100.0 



9811 



-181- 



o 
o 
o 
o 
w o 

<jj in 
w CM 



CO 



8 



8 



0> 



CO 

en 



o 

o 
o 
o 
o 

£ 



o 

o 



8 

o 
o 
o 



t-3 



0) o 
(S: EH 



12 



02 
22 
91 



6 

2 -aoji 

92 
61 



21 

82 
12 



T2 

*2 



LX 

01 

2 •SoT 

AS 



02 
2T 

9 -frpir 

62 




8 



CO i-Jl 



o 
o 



8 

CM 



22 



1A 



9811 



-182- 
ADMINISTRATIVE ORDER X-130 

Interpreting Provisions in Codes which Extend 
Minimum Hourly Rates of Fay to Piece-Workers 



Pursuant to authority vested in the national Industrial 
Recovery Board under Title I of the national Industrial 
Recovery Act by Executive Orders of the President, in- 
cluding Executive Order i\fo . 6859, dated September 27, 
1934, and otherwise, it is hereby ordered that provisions in 
codes which extend the application of minumum hourly 
rates of pay established therein to employees engaged 
on a piece-work basis be and they hereby are intrepreted 
as follows: 

Under any such provision in any code, an employer shall 
compute the minimum compensation payable to each piece- 
work employee on the basis of a period of not more than 
seven consecutive days. Each employer shall -p r >y to each 
of his piece-work employees for work performed by said 
employee during such period an -mount not less than the 
product of the minimum hourly rate prescribed in said 
code multiplied by the number of hours worked by said 
employee during such period. 

If any such provision in a cole as thus aplied should 
work hardship in any case by reason of peculiar circum- 
stances or methods of operation, the employer affected 
thereby may "poly for an exemption to such provision. 

ITational Industrial Recovery Board 

Washington, D. C. By: W. A. Harriman, 

January 1, 1933. Administrative Officer 



NIRA PROVI SIONS :-E7E 20 S TAY: In a recent speech before 
the Construction Industry Meeting at Knoxville, Tenn., Arthur 
D. Whiteside, member of the National Industrial Recovery 
Board said, "It appears inevitable that the major provisions 
of the NIRA in some form will become a permanent part of ovx 
economic legislation." Mr. Whiteside also said that 
modifications of the provisions will be governed largely by 
the actual results obtained through the efforts of the NRA 

up to this time and for the next few weeks. 

* * * 

I II P o a T A IT T ; T ; I C E 
The Code Authority must insist that your payroll reports, 
and label disposition records are filled out and returned 



9811 



•183- 



to us not later than the tenth day of each month. 
If you do your part, the statistics available for the 
industry at the end of the fiscal year willl-'be'. in- 
valuable for every member of the industry. Failure 
to submit payroll reports constitutes a violation of 
the Code . 



• 



I 



9811 



-184- 

CODE AUTHORITY 

LADIES' RAFDBAG- INDUSTRY 

347 Fifth Avenue 
Hew York 



VOL. Ill Ho. 2 IIE'TS DULhETIIi FEBRUARY 20, 1935 



PES I GIT PIRACY : Protection against design piracy for the 
industry has not yet been approved. In the meantime, 
members of the industry who desire to protect original 
designs may do so by making application for a design 
patent. The office of the Code Authority will furnish 
the "accessary information, will give instructions how 
to fill out the necessary documents, and aid you in the 
preparation of the drawing, which must accompany the 
application. A design patent may be procured within 
thirty days of an application. It serves to protect 
the design for 3 1 . years or longer, if required. It 
is enforceable in the Federal Courts with injunction 
proceedings, if necessary. The cost is ten dollars, 
which is the government fee, plus the cost of making 
the drawing. If you are interested in applying for 
design patents, communicate with the office of the Code 
Authority. 



ADnihlSTRATIVE ORDER X-134 

Interpretation: Application of home work provisions 
as contained in various codes. 

P ACTS : Complaints have been received that certain 
employees are engaged in the practice of processing 
articles, the material for which has been furnished 
by the employer, such processing being performed either 
in the home or living quarter? of the employee , or in 
a so-called shop o-oer"tecl within the home or living 
quarters of the employee. 

QUESTIONS : 1. What is meant by "home or living quarters" 
as the term is usee 1 in Codes of Fair Competition which 
provide for the abolition of home work? 



» 



9311 



-135- 



2. Does the practice noted above under "Tracts" constitute 
a violation of such Codes of ~.ir Competition? 

INTEPlFHLTATIOH: 1. The term' "home or living quarters" means 
the private house, private apartment or private room, whichever 
is the most extensive, occupied, as a home "by the employee and/ or 

his family. 

2. The practice of processing articles, the 
material for which has been furnished by the employer, whether 
performed in the home or living quarters of the employee, or 
the so-called shop, operated within the home or living quarters 
of the employee, as the term "ho >e or living quarters" is defined 
herein, constitutes a vi9.le.ti0n of codes which '.provide for the 
abolition of homework; except as provided in" Executive "Order 
6711-A, dated I.Iay 15, 19.34-.' 



Washington, D. C. (Signed) W. A. Harriman, 

January 26, 1035. Administrative Officer 

hat-ion- 1 Industrial Tlecovcry Board 



H AZARDOUS QCCUPATIC-IS: The Labor Advisory Board has recommended 
that minors under 13 be excluded from the following occupations 
in the industry: 

1. As drivers of trucks or other motor vehicles or 
as heloers or delivery boys in such vehicles. 

2. In, or. assisting in, the operation of gas, oil 
or steam engines use' -as prime movers. 

'3. In the operation, custody, or repair of elevators, 

cranes, derricks, or other hoisting apparatus', except 
in the operation, of (l) dumbwaiters as defined by the 
American Standards Association or (2) or elevators- 
equip ed only for automatic operation.- 

4. Firing of ote-T.ni or water boilers (except boilers of 
not more than (15) pounds pressure used solely for 
heating ""mrooses. 



HA1TDIAGS AMD FJRSES "JSTAILIIIC- EOh £5> OH LESS : Preparations are 
being made to include raider the Code of the Ladies' Handbag 
Industry the members of the Imitation Leather and Leather Novelties 



5811 



-136- 



Group who manufacture ladies', misses' and children's handbags 
that retail :from 10^ to 2C<p each. This group was formerly 
included under the Coc.e of the Luggage and Taney Leather Goods 
Industry, hut was released when it became evident that the 
product of these manufacturers could he classed as rightly 
belonging to the handbag industry. The industry includes about 
75 manufacturers, with a volume of sales betvreen four and five 
million dollars. 



In order to facilitate the work of the Code Authority investigators, 
your payroll reports, time cards and other records should be freely 
available for inspedtion. Your earnest cooperation will be appreciated, 

*** ******* * *** **** :!<** ** * ** *:;-. * ■•*::.--* -■ :';*** * * :': :'■- •.;■. :':*** * 

SPECIAL NOTICE 

Article III, Section 2, provides: 

"Ho person enroloj/ed in ship' ir.g, clerical, or 
office work, unless he is employed in a managerial 
or executive capacity and earns no~t less than 'thirty- 
five dollars per week, shall be permitted to work 
in excess of forty hours per week averaged over any 
one month period." 

****:-:.- ^: ***********:' - r * ;fc ;'; r -/- * * * * * * 3|e i 1 ! * A * * sjs : ; * * * * * * *• ->. ■ '- * 

HANDEAG ADS EOR JANUARY 1955 

Ads appearing in the New York Times, American, News, Mirror, 
Evening Sun, and Evening Journal 

Total Number of Ads — 79 
TABULATION SHOWING PRICES ADVERTISED 



Under 




50^ tc 


i 


$1.00 


to 




.00 


to 


$3.00 to 


$5.00 to 


Above 


50^ 




$1.00 




$2.00 




ipO . 


.00 




$5.00 


$7.50 


$7.50 


S.15 


(2) 


$.50 


■ . i 


$1.15 




$2 


.00 


(3) 


$5 . > 


$5.49 


$10.00 ( 


.19 




.59 


(5) 


1.19 


(2) 


2 


,95 


(8) 


4.69 


6.80 


20.00 (; 


.29 




.64 




1.29 




2 


.98 


(4) 


4.95 




9.39 


.39 


(4) 


.68 




1.25 










4.98 




12.75 


.44 




.77 




1.39 


(4) 














.49 




.79 
.89 

.94 


(2) 
(3) 


1.45 
1.48 
1.79 
1.90 
1.95 
1.98 


(2) 
(2) 
.(3) 

(6) 
(2) 














Totals 






















r 


10 




15 




25 






15 




4 


2 


3 



9811 



-187- 







CHART SHOWING NUMBER OF ADS BY GROUPS 




30 




30 












25 












30 
















20 










1 


5 










ft 










10 


10 






















10 


































h 






























1 


h. 








Up to 50^ 


50^ to $1 


$1 to $2 


$2 to ! 


S3 


$3 to $5 


$5 to $7.50 


Over 
$7.50 



COMPLIANCE DIVISION - (January 31, 1935) 
Investigations: 



Number Previously Reported 
Number Made During January 



Total 



Number Non-Compliance Cases Pending 
Number Closed During January 

Restitution: 

Number of Firms 

Number of Individual Employees 
Total Amount Paid $14,625.34 

Total Amount Pending $13,480.00 



1407 
459 



62 
26 



63 
1031 



18oS 



9811 



-188- 

LAEEL DIVISION - (January 51, 193 5) 
REGULAR LABEL SALES 



JUNE 

JULY 
AUGUST 
SEPTEMBER 
OCTOBER 
NOVEMBER 
DECEMBER 
JA1IUARY 
Total 



TOTAL 
1, 220,000. 
2,154,000 
3,529,500 
3,487,000 
4,045,000 
4,310,000 
2,410,000 
3,545,50 ' 
24,693,500 



■WEEKLY AVERA GE 
428,571 
512,857 
741,109 
940 , 806 
879,348 
1,023,080 
600 , 500 
805,540 



Total Sticker Labels . 
(L.ifrs. and Retailors) 



GRAI7D TOTAL 



800,000 



. 35,498,500 



DAILY AVE2AC-I 
85,714 
102,571 
148,202 
188,161 
175,869 
204,516 
120,500 
169,932 



Your special attention is again called to the 
f o llovdng regul at ] ons : 
BLUE EAG LE The use of the Blue Eagle Insignia on any 

cards or labels inserter 1 in bags is absolutely illegal unless 
it is the official label of the Code Authority of the Ladies' 
Handbag Industry. 



CONTRACTORS : This office must be notified immediately upon 



taking Jr. 



any r.ev; contractors. Unl< 



ou register your 



contractors you: are ,ut permitted to issue labels to them. 



2811 



4.189- 
CODE AUTHORITY 
LADIZS' :-AITLEAG HLUSTHY 
347 Fifth Avenue 
New York 



VOL. Ill Ho. 3 _1TEV^^UL^TI1L__ UAECH^1 J J 1 ?35 



BEFUHD: Ac -previously announced in our letter of March 
11, 1935, the Code Authority voted to refund to members 
of the industry the sum of $30,000. out of surplus. The 
amount each member is to receive will he based upon the 
ejnount contributed by him to the Code Authority during 
the budget year from March 26, 1934 to March 25, 1935. 

Such distribution is to be made as soon as possible 
after each member shall report his complete sales up 
to and including March 25, 1935, provided, however, that 
such member will have paid all -mounts cue to the Code 
Authority on -recount o. assessments. 

In order that your refund check may be mailed to you 
withou-: any unneces ary delay, it is imperative that 
you furnish this office rdth your sales figures up to 
and including March 2.3, 1935, and to enclose check for 
amount duo, as soon as possible after that date. Do 
not wait until the end of the month to send us your 
complete figures for March, as the balance of the month 
maybe reported in April, as usual. Those refunds will 
not be credited to your account, but will be issued in 
chock form. 



TFJe are again calling your attention to Article III, 
Section 2 of the Code for the Ladies' H-ndbag Industry: 

"ho person employed in shipping, clerical, or office 
work, unless he is employed in a managerial or 
executive capacity and cams not less than thirty- 
five dollars "'cr week, shall be permitted to work 
in excess of forty hours per week averaged over 
any one month period." 



?611 



-190- 



There seems to "be considerable misunderstanding as 
to this section, in fact, some members feci that the 
Code provisions referring to hours and wage3 do not 
apply to clerical or shipping forces. This provision 
is no less important than any other provision of the 
Code, and violation of this section carries v/ith it 
the sane penalties as provided for all violations of 
the Code. 



EXTRACT TItOM ADiHITISTIUTIVS ?J)E?. NO. X-135 

"Ho member of any industry subject to any Code containing 
mandatory label provisions shall sell, deal in or use 
any label bearing the Line Eagle or bearing any other 
emblem or insignia of the NRA other than that issued by 
the Code Authority for such Industry pursuant to provisions 
of such Code and of this Order. No member of any such 
industry shall sell, deal in or use any label whose form, 
contents or insignia are so similar to a label issued by 
any such Code Authority as to be deceptive." 

This provision does not prohibit the use of tickets or 
labels to indicate the kind or type of leather, etc., but 
does prohibit the use of the Blue Eagle on such tickets. 



Donald R. Richborp, the Executive Director of the National 
Emergency Council, authorized the following statement: 

"I did not submit to the Senate Finance Committee 
on March 13, any list of codes or any number of 
codes, with a recommendation that they should be 
'dropped'. I suggested a method of dealing with 
the problem presented by the Service Industries. 
I also suggested the possible consolidation of a 
large number of small codes and said that if all 
codes covering less than ten thousand employees 
per code should be consolidated into a few codes, 
five hundred and thirty-seven woiild be 'eliminated'. 
This did not mean that codification of these in- 
dustries would be ended, but that the number of 
separate codes could be reduced. There was no 
authority whatsoever for the printing of any list 
of codes, with the statement tint I had recommended 
that they oc dropped. I have not issued any such 
list, or recommended any such policy.' 1 



9811 



-191- 

LALEL REGULATIONS iTOS . 6 -:aC 13 

Your attention is especially called to A r ticles 6 and 

12 of the Label Regulations (copy of which will he found 
on the back of your order blank, form Ho, 4). 

6,- "All labels are to be securely attached to the 
handbag, pockctbook or purse, in a conspicuous 
position on the left-hand side, preferably on 
the mirror pocket •" 

"Securely attached" means either sewn to 
the pocket, or put into the frame. 

13 - "All labels are to be used exclusively by or for the 

firms to whom they are issued." 

Transfer of labels from one manufacturer to .another is 
strictly against the label regulations, and constitutes 
a violation of the Code. This practice c uses confusion 
in records, and makes it impossible to control compliance 
with the provisions of the Code. 



H A1TDBAC - AO S 30?. ZE3 1UA 3Y, 19 55 

Ads appearing in the Hew York Times, American, 
Hews, Mirror, Tribune, Evening Sun, Evening Journal, 
World-Telegram and Post. 

Total llumber of Ads — 119 Total Ilumber of Lines 18,840 

T ABULAJICiT SHOWITC- 1-3I C35 -i3V~3 TISBD 

Under 50{* to $1.00 to $3.00 to $3.00 to $5.00 to Above 
5 0^ $1.0 ■ $3.00 $3. 00 $5.00 $7.50 $7.50 

$.37 (1)$.50 (4) $1.19 (3) $2.77 (6) $3.45 (l) $7.50 (8)$10.00 

(9)- 
.39(12) .59 (3) 1.20 (3) 3.95 (10) 3.35 (1) 12.89 

(1) 
.49 (3) .65 (1) 1.49 (3) 3.98 (o) 4.64 (l) 32.00 

(1) 
.70 (1) 1.50 (1) 3.00 (4) 4.95 (l) 25.01 

(1) 
.79 (1) 1.59 (2) 4.98 (2) 
.94 (7) 1.69 (2) 5.00 (7) 
.95 (1) 1..79 (2) 
1.00 (3) 1.95 (4) 
1.33 (3) 



Tot 1 15 



Average Ad Consists of 158 Lines 



9811 



-192- 



30 


CHART SHOWING NUMBER OF ADS BY GBOUPS 


30 


20 






26 






22 






23 










20 


10 




15 
























13 








12 




10 






■ 




























8 














Up to 50^ 


50<£ to $1 


$1 to $2 


$2 to $3 


$3 to $5 


$5 to $7.50 


Over $7.50 



* * 

STATISTICS 

COMPLIANCE DIVISION - (February 28, 1935) 

Investigations: 

Number Previously Reported 
Number Made During February 

Total 

Number Non-Compliance Cases Pending 
Number Closed During February 

Restitution: 

Number of Firms 

Number of Individual Employees 
Total Amount Paid $14,668.30 
Total Amount Pending $16,000.00 



1866 
554 



91 
22 



64 
1033 



2420 



9811 



-193- 



Analysis of the Industry: 

Humber of Manufacturers 
Number of Contractors 



337 
175 



LABEL DIVISION - (February 28, 1935) 

REGULAR LABEL SALES 



JUKE 

JULY 

AUGUST 

SEPTEMBER 

OCTOBER 
NOVEMBER 

DECEHPER 
JANUARY 
FEBRUARY 
Total 



TOTAL 

1,220,000 
2,154,000 

3,529,500 
3,487,000 
4,045,0 DO 
4,310,000 

2,410,000 
3,543,500 
3 ,092,000 



WEEKLY AVERA GE 

428,571 
512,857 
741 , 109 

940 , 806 
879,348 
1,023,080 
602,500 
805,340 
813,684 



',790,500 



Total Sticker Labels . 
(Mfrs. and Retailers) 



800,000 



DAILY AVERAGE 

85,714 
102,571 
148,202 
188,161 
175,869 
204,616 
120, 50 "I 
161,168 
162,737 



GRAND TOTAL . . . . 23,590,500 



MU E? BEDS : We are in receipt of classification of -muff 

beds by Mr. C. H. James, Executive Assistant, Textile Division, 

as follows: 

"The manufacture of muff beds as such is covered by 
Ladies' Handbag Code except when muff beds are made 
by a manufacturer as an incidental part in the manufac- 
turing of completed muffs when they are included in 
the applicable Code for that manufacturer," 



9811 



-194- 

Lxhibit »C" 

CODL AUTHORITY 
LADIL5' -UIGJAO I1DUSTHY 
347 Fifth Avenue 
ITew Yorl: 



vol. in. ::o. 4 : ~z\:s bullzti:; a? hii 1 2 . 19^5 



PlJsolutio:: 

■'JHEESA3 the Code Authority of the Ladies' Handbag Industry has been 
administering the Code for over a yerr and has had ample opportunity to 
observe the benefits derived under the Code for the industry, and 

T7HEEEAS the Code Authority loxows that previous to the approval of 
the Code, competition was based sole!/ 1 / on the exploitation of labor 
which undermined the industry because of gross inequalities in labor 
costs, and 

VJHSBEAS regardles.3 of riv r ;iistakes that have been :iade, under the 
HRA Act, yet to- the best of their knowledge and belief, the industry has 
shown a reraarJcable improvement u.ue to the operation of the Code, and 

TfiEBSAS it is an unquestioned fact that this Code has reduced 
unemployment, shortened the daily hours of '-orhers, eliminated child 
labor, increased wages as -ell as reduced unfair trade practices 
appreciably, therefore 

3E IT HESOLVLD that the Code Authority of the Ladies' Handbag 
Industry goes on record as heartily supporting the President's request 
to extend the IffiA. 

The pbove resolution which "as passed by the Code Authority at its 
last meeting has been sent to the Members of the L'oxise of Representatives 
and the Senate. However, ^our Congressnar. find your Senator are 
anxious to know your oninion. It is important that individual lenbers 
of the industry add their an u-ovnl to that of the Code Authority. TTire 
or rr rite the Congressnai for "our district, and the Senator fron your 
State, urging then to supoort the President's revest for the extension 
of IJ3A. 

D I T T OJA Y J 



)811 



2420 
738 



-195- 

STATISTICS 

COITPLIAiTCE DIVIS IOi; - (MARCH 31, 1935) 

Investigations : 

lTuriber Previously Reported 
ITu-Vber Jiade Durinr; Ilarch 

Total 3153 

Nunber ITon-Conplir-nce Cases Pending 85 
ITunber Closed During March . 31 

- Institution: . 

ITunber of Pir:is , - 70 

ITunoer of Individual E;^lojrees 1041 

Total Anount Paid ' $1.4,311.22 

Appropriate Anount Pend- $15,000.00 

X'AK 



Analysis of the Industry: 

ITunber of ilanufacturers 

ITunoer of Contractors 



341 
179 



LA3EL DIVI SION - (ilABGH 31, 1935) 



TOTAL 



WEEKLY AVERAGE 



MILY AVERAGE 



JUNE, 1934 1,220,000 




423,571 


85,714 


JULY 


2,154,000 




512,357 


102,571 


AUGUST 


5,529,-: 00 




741,109 


148,202 


3EPTL; 3ER 


5,437,000 




940,806 


183,131 


OCTOBER 


4,044,500 




379,348 


175,35? 


1T0VE] 3ER 


4,310,000 


1 


,025,080 


204,516 


dice:3E" 


2,410,000 




602 , 500 


120,500 


JAllUARY, 1935 3,543,500 




305,340 


151,168 


FEBRUARY 


3,092,000 




315,584 


132,737 


MARCH 


3.754.000 




8 .3,509 


173,751 


Total 


31,544,500 










Totrl Sticker Label 
(jlfrs. and Ret 1 


ile 


875,000' 






L-S) 






GRAI.T) TOTAL 


* 


,359,500 

* * 











9811 



-196- 



haiiTdag ads :'on 'Alien, 1955 



Ads Appep.ri.ng in the V\ew York- Tines, American, L'e-rs, S'irror, 
Tribune, livening Sun, Evening Journal, Uorld-Telegran, Post, 
Brooklyn Eagle, and 3rooliyn Tines-Union 



Total Nuriber of Ads 205 



Total ITunber of Lines— 41,039 



TJDULlTI^:.' SHOTTING PRICES ADVERTISED 



nder 


5C 


<* to 




$1.00 


to $2.01 to 


$3.01 to 


$5, 


01 


to 




Above 


0d 


$1 


.00 




$2.00 


$3.00 


•5.00 


37. 


50 






$7.50 


.10 (1) 




.50 


(4) 


$1.09 


(2):$2.29 (3) 


$3.35 (l) 


$5. 


95 


C 


:0 


:$9.98 (2): 


.33 (2) 




.55 


(1) 


1.19 


(2): 2.39 (1) 


3.95 (1) 


5. 


98 


(: 


.) 


:10.00 (9): 


.35 (2) 




.59 


(7) 


1.29 


(3): 2.77 (3) 


4.64 (1) 


7. 


50 


(i. 


5) 


:10.50 (3): 


.39 (3) 




.53 


(1) 


1.49 


(5): 2.35 (1) 


4.95 (5) 










: 13. 75.(1): 


.42 (1) 




.65 


(2) 


1.59 


(9): 2.95(12) 


4.93 (7) 










:12.93 (1): 


.49 i2) 




.59 
.79 
.37 
.39 
.94 


(1) 
(6) 
(3) 
(2) 
(7) 


1. 65 
'1.83 
1.85 
1.95 
1.98 


(1): 3.93(11) 

(1): 3.00 (4) 

(1): 

(5): 

(5): 


5.00 (15) 










:13.89 (1): 
: 15.00 (3): 
: 15.50 (1): 
s 18.50 (3): 
:33.50 (1): 




1 


.00 


(s) 


2.00 


(5): 












:25.00 (2): 


?otal 11 






43 




41 : 35 


30 








i - 


: 27 : 










Average Ad Con; 


jists of 200 


Li: 


aes 









15 


CHART SH0WI17G 1TUMBER 0E ADS BY GROUPS 

45 








43 








7f\ 
















41 






I 










35 






>0 








30 _ 


































27 








-18 










15 








15 






11 








































i 








i 




Up to 50(*< 


50^ to $1 


$1 to $2 


: 


52 to $3 


$3 to $5 | $5 to $7.50 
1 


Over $7.50 



)311 



-197- 



EXHI3IT '£ 



Letter from Code Director showing division 
of Industry between Leather and Imitation 
Leather. 



9811 



-198- 

EXHIBIT D. 



C 

F 
Y 






September 13, 1935. 



Mr. 0. W. Pearson 
National Recovery Administration 
426 Investment Building 
Washington, D. C. 

a 

Dear Sir: • ■» 

Answering your inquiry, , the percentage of bags made 
of leather figured in dollar value, i*s about fifty per cent, and 
fifty per cent imitation leather, including all other fabrics. 

Figured in units, the percentage of bags made of 
leather is about thirty per cent, and seventy per cent of imitati 
leather. 

I trust this will give you the desired information. 

Everybody here joins me in sending our kindest regards. 

Sincerely yours, 



on 



(Signed) A. Mttenthal 



AM: AS 



9811 



-199- 



EXHI3IT E 



Division of Economic Research and 
Planning Brief 



9811 



EXHIBIT "E" 

NATIONAL RECOVERY ADMINISTRATION 
DIVISION OF ECONOMIC RESEARCH AND PLANNING 



LADIES', MISSES' AND CHILDREN'S HANDBAGS INDUSTRY 

Prepared by 
James P. Davis 



Approved "by 
Andrew T. Court, Unit Chief 

First Edition 



February 8, 1934 



9811 



-201- 

LADIES', MISSES' AND CHILDREN'S HANDBAGS 

Number of Employees 

On the basis of Census data supplemented by statistics presented 
by the industry, it is estimated that the average number of employees 
in the Ladies', Misses' and Children's Handbag Industry in 1929 was 
about 10,000. 

Summary 

This is a young and growing industry. Hours should be further 
shortened. There are a few objections to certain minor provisions. 

Scope and Size of the Industry 

As defined in the proposed code, the industry includes the manu- 
facture of handbags, pocketbooks, and purses for ladies, misses, and 
children. All materials are included, but the manufacture of pocket- 
books and billfolds for men is not so included. 

The industry as so defined has in recent years represented an 
annual volume of business ranging from a maximum of about 67 million 
dollars in 1929 to about 35 million dollars in 1931 and 1932. The 
development of the industry from the first decade of the century has 
been rapidr and it is still in an early phase of its life cycle and can 
be expected to maintain and perhaps further increase its importance. 
Taken in connection with the fact that it is now operating at maximum 
volume of production, this condition of vigorous growth indicates that 
this industry should be expected to continue increasing employment and. 
could readily submit to further restriction of hours for that purpose. 
The following table shows the increase in employment and volume since 
1921: 



Wage 


Value of 


Earners 


Fro duct 




(Thousands) 


2,715 


$13,085 


5,518 


32,732 


6,826 


43,105 


8,570 


57,345 


10,430 '■'■' 


68,628 


8,747 


43,147 


12,000 ' 


35,000 


12,000 • 


35,000 



1921 
1923 
1935 
1927 
1929 
1931 
1932 
1933 

Source: 1923 - 1931, Bureau of Census. 
1932 and 1933 - Report from the 
industry. 

It may be noted that an average of about 7 per cent of employment 
and volume produced should be deducted from these figures to cover the 
production of men's pocketbooks and billfolds. 

9811 



-202- 

Geographically, the industry is concentrated to a large extent 
in the East-New. York having in 1929, 192 establishments; Pennsylvania 
and Massachusetts, 17 each; Illinois, 10; New Jersey, 9; and ; California , 
11. The total number of establishments in the entire country was about 
200. 

Employment, Hours and Wages 

The best available figures indicate that the average hours worked 
in the industry prior to the adoption of the. President ' s Reemployment 
Agreement were about 48 per week. The adoption of the President's Re- 
employment Agreement, giving theoretically an increase of 20 per cent 
in employment to offset restriction in hours, has probably produced an 
increase of about 15 per cent, or a total increase in employment of 
about 1,800. 

On account of the fact that most of the workers in the industry 
were receiving somewhat more than the minimum set by the President's 
■Reemployment Agreement, the increase in payroll corresponds roughly 
with the increase in employment. It is believed that there has been 
no extensive increase in average earnings. No definite figures are 
available on this point at this time. 

The labor cost in this industry is relatively high because of the 
rather large amount of detail work necessary on handbags. For 1929 
the ratio of wages paid to value added was 45.8 and in 1931 - 47.7, as 
compared with 36.4 and 36.3 in general manufacturing. In a general 
way, labor cost may be set at about 25 per cent of wholesale price of 
the merchandise of the product. It follows that an increase of 4 per 
cent in labor cost would be reflected in an increase of 1 per cent in 
wholesale price. If therefore hours were further shortened to 35 
producing an increase of about 15 per cent in labor cost and weekly 
wage scales were maintained, the effect on wholesale prices would be 
approximately 4 per cent increase. Since this merchandise is usually 
sold in retail trade with a large mark-up, it seems that there should 
be no great difficulty in further restricting hours, particularly in a 
period of rising prices when the addition of a reasonable amount to the 
retail price of a handbag would not be a serious handicap to its sale 
by the retail store. The only difficulty is that most articles of this 
type are grouped by retail stores into certain price classes such as 
$1.69, $1.98, $2.54, $2.98, etc. It may frequently happen that a slight 
change in the wholesale price would make it necessary to move the article 
into the next higher price class causing a much larger mark-up. One of 
the largest retail establishments in the country urged this point strong- 
ly in the hearing. 

Comments on the Code 

The Code, as now revised, is generally free of controversial pro- 
visions and, with a few exceptions, no objection is seen to its approval 
as drafted. 



9811 



-203- 

In Article IV, Section 6 there is a provision which contemplates 
the establishment, of classified wage scales for the industry. Since 
the establishment of classified wage scales under codes is contrary to 
to Administration policy, it would seem wise to eliminate this provi- 
tion. 

In the trade practices, Article VIII, Paragraph 3^ the paragraph 
prohibiting the use of misleading advertising or selling methods also 
prohibits the use of misleading credit terms. The application of this 
provision is not clear, and it would seem that credit terms should be 
dealt with in other sections of the Code. 

Paragraph 8 prohibits the payment of all rebates and other forms 
of allowance. While there is no objection to the prohibition of secret 
rebates, it seems that the clause as written might restrict many legit- 
imate and established trade practices. 

Paragraph 12. Recent developments nave brought the uniform dis- 
count clause of trade practices under criticism, and it is suggested 
that unless the proposed clause conforms closely with the well-establish- 
ed practice of the industry, it might contribute further cause for such 
criticism. 

Paragraph 14. This paragraph prohibits all forms of return of 
merchandise after seven days and severely restricts returns within 
that period. It is questioned whether so stringent a provision as to 
the return of merchandise would be equitable under all conditions. 

Prepared by _^___ 



Froject Supervisor 



Read and Approved by 



Unit Chief 



JPD:hls 
2-8-34 



9811 



-204- 



EXHIBIT F 






Statistics 



9811 



-205- 
EXHIB I T | 

COD'S AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 FIFTH AVENUE 
NEW YORK 



March 13, 1935. 



Col. Walter Mangum' ' 
Deputy Administrator 
NRA, Division 3 
Commerce Bldg. 
Washington, D. C. 

Dear Col. Mangum: 

We are submitting for approval the "budget for the Ladies' Handbag Indus- 
try as approved by the Code Authority at a meeting held March 7, 1935 at 
the Hotel McAlpin, New York. 

Period This budget is for the -period beginning March 26, 1935, and 
ending March 25, 1936. 

Amount The total amount of the budget is $110,641. The budget is di- 
' . vided into two neriods — one from March 26, 1935 to June 16, 
1935; the second from June 17, 1935 to March 25, 1936. 

Rate The rate of assessment if one-fourth of one -oer cent of the 
sales of the members of the industry. 

The total volume of sales for the industry is estimated at 
$45,000,000. The total income from assessments at the rate of 
one-fourth of one -oer cent should amount to $112,500. 

Labels There will be no change in the urice charged for labels of 

$2.50 ?er thousand, since the total price paid for the labels 
is credited at the end of the month to the amount of assessment 
due. In the case- of the makers of low nriced bags, the amount 
■oaid fur the labels during the month should exceed the amount 
of the assessment due, in which case the difference is refund- 
ed by allowing a credit on the next purchase of labels, or by 
check if requested. In the case of makers of high priced bags, 
the assessment generally amounts to more than the amount ad- 
vanced for labels, in which case the difference is t>aid to the 
Code Authority. 

Present The present budget expires on March 25, 1935. The budget was 
Budget estimated at $133,540, and the method of assessment was based 
on one-third of one x>er cent of volume of sales which it was 
estimated would be $45,000,000. The Code was effective March 
26, 1934 but the use of labels was not made effective until 
July 2, 1934. During this neriod no income from assessments 
was available for Code work so that the activities of the Code 
Authority were necessarily limited and very little expense was 
incurred during the first three months. 

9811 



-206- 



Amount of On the "basis of sales figures as re-ported ur> to January 31, 
Assessments 1935, and estimating the sales to the end of the budget 

period, March 25, 1935, the total assessments due from mem- 
bers of the industry will amount to about $115,000. 
The amount actually expended for Code work up to January 31, 
1935 toIus the estimated expenses to the end of the budget 
period, March 25, 1935, will amount to about $73,000,, 
leaving a surplus of approximately $42,000. The Code Author- 
ity passed a resolution to distribute, at the end of the 
budget year, March 25, 1935, $30,000,00 of this surplus to 
the members of the industry in proportion to the amount con- 
tributed by each member to the Code Authority during the 
budget year. 

The balance of the surclus amounting to about $12,000. will 
be allowed to remain with the Code Authority so as to 
insure funds for the continuation of Code work. 

Compara- The new budget, from March 26, 1935 to March 25^ 1936, is 

tive to be $23,000. less than the old budget from March 26, 1934 
Budget to March 25, 1935. 
Figures The rate of assessment is reduced from one-third of one 

per cent to one-fourth of one per cent. 

The method of assessment will remain the same, being based 

on the vclume of sales, to all members of the industry 

al ike , 

The price of labels will remain the same, $2.50 a thousand. 

The method of assessment will remain the same — the total 

amount paid for labels will be credited against assessments. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 



AM:R:AS (Signed) A. Mittenthal 

A. Mittenthal 

Code Director 



9811 



-207- 
C P Y EXHIBIT F 



CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

347 FIFTH AVENUE 

net; YORK 



March 13, 1935 



Col. Walter Mangum 
Deputy Administrator 
Commerce Bldg. 
Washington, D.C. 

Dear Col. Mangum: 

I transmit herewith for your approval the budget for this Code Authority 
from the period March 26, 1975 ending March 25, 1936, together with cop- 
ies of the resolutions nassed by the Code Authority. 

This "budget shows a substantial reduction over that of the nreceding one. 
There are hut one or two items to-whieh I believe it necessary to draw 
your special attention. The first is "Handbags Furchased - $200." This 
Code Authority has from time to time found it necessary to purchase bags 
advertised and displayed in the stores, so that they may check sources 
of supply and curb, wherever found necessary, unfair advertising state- 
ments made by various outlets. 

The second are 'two items of $5000. each, for "Statistical Work", and 
"Trade Development and Research". This Code Authority has during the 
oast twelve months be^n endeavoring to get together a picture of this 
industry to the end that industry might better know itself, and possibly 
therein find the answer to some manufacturing and distributive problems 
that have troubled them for so long. A good start has been made, and 
I feel that this type of work should be encouraged. 

Taking. the budget as a whole, it meets my entire approval. Each item 
in it has been carefully weighed and I think the Code Authority is to 
be commended for the care with which they have a-ooroachcd this important 
matter. I therefor ask your approval of it. 

Very truly yours, 

i * 

0WP:E:A CSignedl 0. W. Pearson 

0. W. Pearson 
Administration Member 
Code Authority Ladies' Handbag Industry 



9811 



EXHIBIT F 



BUDGET 



CODE AUTHORITY 
for the 
LADIES' HANDBAG INDUSTRY 

*** 

1. Title of Code Authority: Code Authority Ladies' Handbag Industry. 

2. Address: 347 Fifth Avenue, New York, N. Y. 

3. Budgetary Period: From March 26, 1935 to March 25, 1936. (12 Months) 

(If the NBA is not extended "by Congress on or about June 16, 1935, 
the budget will be effective to that date only.) ' 

4. Effective Date of Code: March 26, 1934. 

5. Assessments are based on l/4 of l4> of the sales of manufacturers and 
manufacturing jobbers. Contractors are not assessed. The sales for 
the industry are estimated at $45,000,000. At the rate of 1/4 of 1$, 
the assessments will amount to $112,500. 

The rate of l/4 of 1$ mentioned above applies to the new budget for 
the forth-coming year. This is a reduction from the former rate of 
l/3 of Vfc in effect throughout the first year of operation. 

The' method of collecting the assessments is as follows: Labels are 
sold to the manufacturers and manufacturing jobbers at the rate of 
$2.50 per thousand labels. This total amount is credited as an ad- 
vance against the assessments. In the following month after purchase 
of labels, the manufacturer reports his sales at l/4 of 1$, applies 
his advance credited to him at the time of purchase, and remits for 
the difference, or is credited by the Code Authority, depending uoon 
whether the difference is due to the Code Authority or due to the 
manufacturer. In the latter case, he applies this credit on his 
next purchase of labels. 

The record of labels sold applicable to last year's budget is as fol- 
lows: 

Estimate of Label Sales from March 26, 1934 

to June 18, 1934 (date of first sale) 10,000,000 labels 
Number of Labels actually sold from June 18, 1934 

to January 31, 1935. 25,262,200 

Estimated February 1, 1935 to March 25, 1935 6.000.000 " 

Total Labels for Old Budget Period 41,262,200 " 

The estimate for the new budget for the period March 26, 1935 to 
March 25, 1936 is 65,000,000 labels. This estimate is divided into 
45,000,000 of the labels sold to the present members of the industry, 
and 20,000,000 to be sold to the two new groups, Imitation Leather & 

9811 



11 



-209- 



Novelties Industry, and Shopping Bags, Bathing Bags, etc. Industry, 
which are soon to be included under the administration of this Code 
Authority. 



PROTECTION OF FUNDS : 

(a). Designation of the -person or -persons who will receive and account 
for all funds. 

Answer : Executive Director, Compliance Director, Treasurer and 
Secretary. 

(b) The giving of adequate security by him or them. 
Answer ; Adequate bonds. 

(c) The segregation of Code Authority funds from all others, separate 
bank accounts being necessary. 

Answer : Funds are deposited in two banks and those deposits are 
mada up of Code Authority funds only. 

(d) The keeioing of accurate records or records and disbursements, of 
amounts levied, of amounts receivable, of amounts payable, and of 
commitments. 

Answer: Complete detailed and accurate accounting records made of 
all income and expenditures* 

(e) The submission of periodic reports to NBA, 

Answer: Monthly audited statements by independent outside firms 
of Certified Fublic Accountants submitted to NBA. 

(f) An annual- audit by independent outside competent agency. 
Answer : Annual audit made by independent outside firm of Certi- 
fied Fublic Accountants submitted to NBA. 



9811 



-210- 



If assessments are based on classes of establishments, explain the "basis 
of classification and indicate the number of establishments of each class: 

Assessments are "base: 3 on the sale-, of manufacturers and manufacturing 
jobbers of which hhere J^e approximately 325 concerns. Contractors, who 
number approximately 175, are not asitJSoed. 

General Inf oimab' o n; •""■' 

a. Number of establishments in Industry • 500 

b. Number of es ■abli-.h^ents to l.e assessed : 325 

c. Number of establishments which nave paid assessments 325 

d. Annual sales for 1D34-1935 $35,000,000 

e. Aiaount of sales, ou which assessments have been 

collected t:> date $'26,093,664 
f« Volume cf sales on vvhich assessments will be 

collected $ 7,000.000 

g. Uuail'er cf employees as of DoceTibs:? 31, 1935 15.000 

h. Tot,:.] annual payroll : fo i Iridvs'.-ry for 1934-1935 $' 9,000 , 000 
i. Geographical distribution of ':ar-,'ac'i'.rers; 

Sales volune for the reiio^ starting March 26, 1934 
and endirg Pecem'bei 31 ,, -1934, base'd on reports submitted 
by manufacturers up to January 31, 1935, 

Area Ne_: k ales , per C^nt 

Eastern . $23,8-'" t50 91 r >0 

Southern 601 4(31 2*&$ 

Midwestern l 5 332 ; <ttf0 5.1-3 

Pacific Coast 225,043 to. 67 



Total $26,093,654 100.00 

Explanation; 

Eastern - - ~ - New York, Massachusetts, Connecticut, Rhode Island, 
New Jersey, Pennsylvania; 

Southern- - - - Maryland, Virginia, Florida, Texas 

Midwestern - ~ - Illinois, Wisconsin, Missouri, Ohio 

Pacific Coast - Washington, California. 



9811 



-211- 



EXHI3IT F 



EXHIBIT A 



SALARIES 



Executives 



Position 



Mr. A. Mittenthal - Chief Executive Director 
Mr. K. Berkowitz - Director of Compliance 
Mr. M. S. Kosesson~D::ecutive Secretary 



Clerical 

R. A. Segner, 
Waters 
Cohen 
Feller 
Levine 
VJohlfeld 
So s an sky 



C. 
P. 
II. 

E. 
D. 
A. 
Y. 
J. 



Total Dxecutive Salaries 



Sec'y. to Compliance Director 

Bookkeeper 

Ass't. Bkkpr. & Statistical 

Stenographer & Statistical 

Stenographer 

Operator 



Steno. c; Tel 

Stenographer 
C-rodzinsky Stenographer 
Brodkin Label Clerk ■ 

Total Clerical Salaries 



Time Devoted. 


Salary Annual 


to Position 


per Ueek Total 


>r Fall Time 




$10,400.00 


ii 




$10,400.00 


ii 




$ 5.200.00 
$26,000.00 


• Fall Time 


$25. 




ii 


31. 




ii 


18. 




ii 


17. 




it 


19. 




ii 


IS. 




ii 


23. 




it 


17. 




n 


20. 






$188. 


$ 9,852.00 



Comments on Clerical Salaries : The above schedule contemplates an 
increase of three dollars per week for all clerical employees. 
These employees ^Till have he,en with us more than one year and will 
he entitled to 'such increase. 

The Executive Secretary receives $5000. per annum at the present 
time even though the intention- was to pay him $5200. per annum. 
This will take effect starting with the new budget. 



Investigators ; 

L. Herzbach 

D. Sobel 

M. Rosenberg 

I. Schor 

One additional 



Chief Investigator 

Investigator 

Investigator 

Investigator 
Investigator 

Total Investigators' Salaries 



Full Time 
11 


$60. 
40. 


11 

11 
n 


30. 

27. 

40. 



$197. $10,324.00 



Comments on Investigators* Salaries ; ■ The above schedule 

contemplates the following increases: 
L. Herzbach $10. 
Ii. Rosenberg 5» 
I. Schor 5» 

The first two will have been with us a year and. are fully experienced. 
Mr. I. Schor is now hired, at a trial salary at $22. and. as soon as he 
is experienced, he will be given his increase. 

Total Salaries $46,176.00 



9811 



-212- 
EXHIBIT F 

EXHIBIT B 

REGIONAL OFFICES 



Provision is made in the "budget for regional offices to "be set up and 
funds to be alloted as follows: 

Chicago $ 3,000 

Pacific Coast 2.000 

Total $ 5,000 

EXHIBIT C 

LEGAL FEES 

The "budget contains no provision for legal fees. 



EXHIBIT D 

TRAVELING EXPENSE 

Members of Code Authority 

Payment is made on the basis of expense vouchers submitted by such 
member for each individual trip. 

Employees 

Mr. Sobel, an investigator, receives $4.00 per day for out of town 
trips to New Jersey, Pennsylvania, New York State, Connecticut, Maine, 
Rhode Island, Maryland, Virginia, etc. This figure will have to be 
increased to $5.00 per day to reimburse him for proper expenditures. 

All other employees, and Mr. Sobel, when in metropolitan area, are 
paid for traveling expenses on the basis of expense vouchers submitted 
by each individual. 

Approval 

■ All expense vouchers must bear the signature of' the recipient of the 
money, and the approval of the following: 



Mr. M. S. Mosesson, Executive Secretary 
and either Mr. M. Berkowitz, Director of Compliance 
or Mr. A. Mittenthal, Executive Director 



9811 



-213- 



EXHI3IT 1 

EXHI3IT E 

COMPLIANCE FUNCTIONS 

March 26, 1935 June 17, 1935 

to to Total 

Salaries June l6, 19^5 i'.ar. 26, 1936 



Mr. Berkowitz, Director 


f 








Compliance 






$ 


2,343. 


Miss Segner, Secretary to 


Dir, 


1 






of Comp. 




$25. 






Miss Grodzinsky, Stenogra; 


oner 


17. 
$42. 




496. 


Investigators 










Mr. L. Merzbach, Chief 




$60. 






Mr. D. Sobel 




40. 






Mr. M. Rosenberg 




30. 






Mr. I. Schor 




27- 






One additional 




40. 










$197. 


$ 


2,324. 


Handbags Purchased 






$ 


50. 



$ 8,057. $10,400. 



$ 1,705 2,201 



$ '3,000. $10,324 

$ 150. $ 200 

Regional Office Expense (See Exhibit B)$ 2,000. $ 3,000. $ 5,000 

Traveling Expenses (See Exhibit D) S 1.S00. $ 4.700 S 6.500 
Employees 

Total Compliance Amotions $ 9.01^ S25.612 $34.625 



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EXEIIH & 

Brief prepared by A. Mittenthal, former 
Code Director 



9811 



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-223- 
EXHIBIT "G-" 

Prepared "by A. LIITTEKTHAL 
former CODE DIRECTOR 
September 1935 

The principal problems confronting the ladies' handbag industry be- 
fore the code, were competition based on unequal labor standards, and com- 
petition based upon unfair trade practices. The labor problems were the 
result of the migration of the industry from the metropolitan area of New 
York to cities located in Massachusetts, Connecticut, New Jersey and Penn- 
sylvania. This migration began in ■ the year 1929, and continued increasing- 
ly up to and during the period of the NBA. 

Up until the year 1929, more than 85$ of the industry was located with- 
in the metropolitan area of New York. The industry located in New York has 
been in contractual relations with the Union for about twenty years. In 
the year 1928, the first manufacturer moved away from the unionized center 
of metropolitan New York, and began manufacturing in Allentown, Pennsylvania, 
under non-union conditions. At this time, the Union minimum wages fixed by 
agreement with the manufacturers in New York were $45.00 a week for skilled 
workers. Admission of workers to the jailed branches was controlled by the 
Union, so that in some of these branches of the industry workers earned on 
a piece work basis from $100.00 to $200.00 in a 44 hour week. Those manu- 
facturers who moved from New York Mere unable to obtain skilled workers in 
their respective localities. They were compelled to employ workers without 
any previous experience in the industry. Machinery heretofore little used 
in the industry, was invented to take the pice of many of the operations 
performed by skilled workers in the New York factories. Workers in these 
new localities were paid $6.00 or $7.00 a week, and they worked from 48 
to 54 hours a week. 

TTith this tremendous difference in labor costs, those manufacturing 
outside of New York, were able to give greater values or sell for less, 
with the result that the manufacturers operating In New York under Union 
conditions were forced to meet this competition by sacrificing their profits. 
The success of the few who moved away, offered the incentive for others to 
follow. In the year 1933, only about 50$ of the industry still remained in 
the metropolitan area of New York. Those who moved or opened new factories 
located in the eastern states, a few in the Chicago area, and a few small 
units were scattered throughout the country, chiefly on the Pacific Coast. 
The Union was unable to establish Union conditions in these factories outside 
of New York. The facotries remaining in New York, were chiefly those making 
the high grade handbags which required the most skillful workers. 

At the time the code was being drafted, the industry was about equally 
divided between those manufacturers having contractual relations with the 
Union located in New York, and those without Union conditions, ail of whom 
were located outside of New York. Factories in New- York were paying first 
class workers (by Union agreement) $35.75 a week, and second class workers 
$32.00 a week; general help about $18.00 a week for a 44 hour week. Factor- 
ies outside of New York were paying their best workers about $20.00 to $22.00 
a week, and general help from $6.00 to $8.00 a week, for a 48 to 54 hour week. 
Bitter struggle resulted because of the efforts of the Unionized factories 
to establish in the code a classification of the workers according to their 

9811 



-224- 

skill, and the operations performed,' at wage scales approximating those that 
were being paid in Union factories. Those manufacturers not Unionized, fought 
to prevent the classification of the workers and the establishing of wage 
scales in the code above the minimum of $14.00, claiming that their work- 
ers were not skilled, that the system of work employed in their factories, 
known as the "section system" (not permitted in a Union factory) did not 
require any skill; that new machinery and new methods revolutionized the 
manufacturing of ladies' handbags, particularly in factories making low 
price bags of cloth, (imitation leather) to retail at one dollar or less. 
At this time, 80$ of the manufacturers making these cheap bags were located 
outside of metropolitan New York, 

Trade associations were formed by the opposing interests, and legal 
advice was employed by each faction to prevent the unfavorable action by 
the other. 

The final approval of the code was not the result of a compromise 
between the factions on the matters at issue, but because the Divisional 
Administrator had ruled against the inclusion in the code of any classifi- 
cation of the workers, or any wage scales above the minimum. Later this 
was modified to allow one additional wage scale above the minimum for semi- 
skillsl workers. However, in the order approving the code, this provision 
was stayed, until the term "semi-skilled" could be defined by the industry. 
The conflict .between the factions continued after the approval of the code, 
when attempts were made to define the term "semi-skilled*" A number of 
hearings were held in New York and in Washington, and attempts made to com- 
promise the matter. The Union was active in trying to have the order stay- 
ing Sections 2 and 6 of Article IV vacated, (these sections related to the 
establishment of the rate above the minimum for semi-skilled workers, and 
the provision for the classification of workers more skilled). The outside 
imufacturers, thru the Code Authority, voted to have these two sections de- 
leted from the code. 

In September 1934, the Union, unable to effect a new agreement with 
those manufacturers still remaining in the metropolitan area of Hew York, 
called a strike. The strike lasted about five weeks. In the interval, more 
manufacturers moved away from New York to outside locations. About 80$ of 
the industry was then located outside of New York. Some of these manufactu- 
rers who moved away were those who had persistently fought the outside manu- 
facturers in an effort to equalize labor costs. As soon as they moved, they 
fought just as hard against the New York Manufacturers in an effort to gain 
every advantage in labor costs. The final settlement of the matter had not 
been reached at the time all codes were voided. 

The President's blanket agreement issued prior to the approval of our 
code, called, for a minimum wage of $12.00 a week, and 40 hours a week. 
About 75$ of the outside manufacturers adopted the 40 hour week at once. The 
Union agreement made the 40 hour week automatic in factories in New York. 
About 60$ of the industry outside of New York raised the minimum wages to 
$12.00. Union factories were not affected. They did not employ any workers 
lower than $14.00 a week. At the time the code for the industry wa,s adopted, 
the wage scales in the industry resembled somewhat a toboggan slide, going 
from $35.75 a week (the minimum demanded by the Union for skilled workers) 
down to $6.00 a week paid in some outside factories. The code made a mini- 
mum of $14.00 a week mandatory. Abeut 80$ of the manufacturers complied imm- 
'ediately. The 20$ who did not comply, could be classified into three groups; 

9811 



-225- 

those who sought temporary advantages, expecting it would take time before 
they could be investigated. These manufacturers paid restitution, ana com- 
plied fully thereafter. 

Another class, resorted to falsification of records to hide non-com- 
pliance. They too eventually paid restitution, hut had to be policed closely. 
The third class, were those who used the most ingenious methods of deception, 
resorting to coercion and intimidation of their workers, refusing to keep 
any records, or destroying records, and who employed lawyers to defend them, 
and who we finallv had to bring before the Compliance Board in Washington, 
fortunately, this was the smallest class, not more than 2# of the industry. 
There are some interesting records of these cases in the department in 
Washington. 

A sroun of manufacturers located in eastern Massachusetts, manufactur- 
ing a particular type of handbag, employed children from ten to sixteen years 
old, to weave strips of leather by hand. This work was done m the homes. 
The. prices paid for the work were so low, these children were compelled to 
work frequently until midnight. Under the code, child labor in this branch 
of the industry was stopped, and the work was taken out of the homes, and 
brought into the factories. 

In the beaded branch of the bag industry, most of the beading is done 
in the homes. It was found impossible to transfer this work into the fac- 
tories on account of the scattered localities in which the homework is done. 
However, control of these workers was effected, with the result that the 
prices paid these homeworkers were raised from about 7^ an hour to about 2^ 
an hour. 

In the year 1929, the sales volume for the industry amounted to about 
70 million dollars. Using the 1929 figures as a basis the sales volume for 
the year 1930 decreased about 30#. In 1931 - 40&. in 1932 - 60?*, in 1933 - 
5556, and 1934 about 50jS. This decrease in sales volume created a very serious 
situation to manufacturers who had an overhead expense that could not be _ 
readjusted quickly. A few manufacturers, because of the necessity for their 
maintaining a large, sales volume, entered into agreements with some large 
retailers to give them rebates on their purchases, in consideration for 
which such retailers Promised these manufacturers that they would make them 
preferred resources. " The system of rebating grew rapidly in' the industry, 
starting at 2% and increasing to 50. Small manufacturers who were unable 
or unwilling to 'offer rebates, found it difficult to sell to many of these 
large distributors. 

The average ladies' handbag contains about twenty different materials, 
and requires about thirty main operations to complete. A general lack o± 
the knowledge of computing costs b-, the manufacturers in the industry, has 
resulted in ruinous competition. The standards of value are set so high _ 
by these manufacturers, being ignorant of their costs, that the most effici- 
ent manufacturers find it impossible to compete except thru the sacrifice of 
their profits. Strangely, it is a few of the largest manufacturers m the 
industry who are responsible for this ruinous competition. Their practices 
having resulted in financial readjustments of their businesses at various 
times. Some manufacturers engaged in unfair-trade practices, such as selling 
on consignment, or on a guaranteed sale, paying for retailers' advertising _ 
giving rebates, and granting excessive terms of sale. Because of these unfai, 
trade practices, small manufacturers, and those who tried to follow sane 

9811 



-226- 

business principles, were restrained from selling some of the largest dis- 
tributors of ladies' handbags in the country. 

Previous to the code, the discount allowed purchasers for the prompt 
payment of their invoices was not observed to any great extent, payments 
being made long after the due date with the full amount of discount deducted, 
Pew, if any manufacturers, were willing to return checks for this reason, 
fearing to incur the displeasure of their customers. As a result, hot more 
than 40$ of all accounts were paid promptly on the due date. When the code 
prohibited the granting of discounts in excess of 3/10 eom, the manufacturers' 
records show that fully 80$ of their customers paid promptly on the due date, 
in order that they might earn the cash discount. 

The trade practice rules under the code benefited the industry great- 
ly. They furnished the manufacturers a reason for refusing the demands of 
the retailers to engage in unfair trade practices. The most important and 
beneficial trade practice rule was the one which fixed the terms of sale for 
the industry. The reason for the industry failing to show a profit for the 
first four years of the depression, was due perhaps more than anything else 
to the granting of discount and terms wholly unwarranted. The industry 
earned not more than 1$ in discounts and granted 8$. More than 50$ of the 
manufacturer's cost represents a cash outlay', yet the industry was forced to 
grant terms of 30 to 45 days from the date of shipment. 

In a number of cases, manufacturers refused to avail themselves of the 
benefits afforded them by these trade practice rules in the code, and 
continued some of these unfair trade practices, despite the efforts of 
the Directors of the code to prevent them f ron doing so . The most effec- 
tive instrument for compliance under the code was the label. The cooper- 
ation given by the retailers in refusing to accept any product of the indus- 
try without the label, .had the effect of restraining the manufacturers from 
violating the code. 

In the year 1934, the first year of the operation of the code, the 
handbag manufacturers reported profits, most of the manufacturers reporting 
their first profits since 1929, others reported more profits than any year 
since 1929. The supply houses selling to the handbag manufacturers report- 
ed a feeling of greater security in selling to the industry. The manufacture 
ers were meeting their obligations more promptly, and there were fewer fail- 
ures in the industry than there had been in five years, past. The retailers 
reported an increase in the sales volume of handbags, due in great part to 
the incentive given to create more and attractive styles of handbags, be- 
cause the manufacturers were operating on a profitable basis. 

There were not any great difficulties encountered in organizing for code 
administration, other than the settlement between factions in the industry 
as to the number of representatives each was entitled to have on the Code 
Authority. All other matters were left to the Directors of the Code Authori- 
ty to take care of, which were approved by the industry. The matter of re- 
presentation on the Code Authority was adjusted when a number of important 
manufacturers moved their factories away from New York and joined the ranks 
of outside manufacturers. Opposing trade associations were then merged and 
there was little or no further opposition. The industry had no difficulty 
in financing code administration. Labels were sold at $2.50 a thousand 
alike to all manufacturers. The amount paid by a manufacturer for labels 

9811 



.. -227- 

each month was credited against his assessment based on l/3 of 1$ of the 
volume of sales each month. Adjustments were made with the manufacturers 
at the end of each month. The system was equitable to all manufactxirers, 
and operated perfectly. Assessments -were collected each month and com- 
pliance on assessments was had almost one hundred per cent. At the end' of 
the first fiscal year, the Code Authority had a surplus of $41,000 of 
which amount $30,000 was returned to the members on a basis of the amount 
each contributed. For the following year, the rate was reduced to ^ of 1$. 

The work of administering the code was divided between two Directors 
and an Executive Secretary. One Director had charge of the labor provis- 
ions, the other Director of trade practices and planning and research; the 
Executive Secretary supervised' the office staff, the statistics and label 
distribution. Each Director was familiar with the work of the other, and 
the work was planned so that all of the work was thoroughly coordinated. 

The greatest difficulty encountered in securing compliance was due to 
the overlapping of our code, with industries who made handbags in addition to 
other products, which came under other codes. They competed strongly with 
the manufacturers who ms.de handbags exclusively. An important ruling on 
this matter was made by Col. Brady, which definitely placed all handbags made 
of any kind or nature, under our code. However, we had difficulty in making 
other Code Authorities accept this -ruling. The matter was adjusted satisfac- 
torily just at the time the codeswere declared invalid. We also found diff- 
iculty in enforcement, because a branch of the industry making the very cheap- 
est grade of handbags had been allowed to become a division of the luggage 
code. This branch of the industry seriously interfered with the manufactur- 
ers making low price goods under our code, because labor conditions were 
more favorable under' the luggage code, they preferred to remain under this 
code. We made application to have this branch separated from the luggage 
code, and. put under our code, so that the industry would not be divided into 
two codes according to price goods. The transfer of this group from the 
luggage code to the ladies' handbag code, had just been accomplished when 
the codes were declared invalid* 

Under labor compliance, our chief difficulties' were encountered with 
only a few manufacturers who tried to cthisel on the hours and wages. Some 
of these violators were ordered to pay restitution to their workers, mount- 
ing to many thousands of dollars. In some- of the most flagrant cases, monies 
due the workers for restitution were ready to be paid when the codes were 
voided. 

We can definitely state that 75$ of the industry immediately accepted 
the code as being the law of the industry, and that they complied with it 
fully.. The remaining 25$ soon learned that chiseling. on the code, to gain 
a monetary advantage, did not pay. We are certain that in another six months 
under the code, the industry would have had very nearly 100$ compliance with 
the code. 

The strong features of the KRA. administration under codes was the gen- 
eral respect the manufacturers had for any law or ruling that had the back- 
ing of the government. The manufacturers accepted the labor provisions and 
trade practice rules as benefits in that they were protected from their com- 
petitors who were restrained from indulging in harmful practices. At first, 
there was uncertainty as to the ability of the Code Directors to control the 

9811 



-228- 

di startling elements in the industry. After a short time under the code, 
the manufacturers realized that this was being accomplished, and they readily 
fell in line. It was admitted by the manufacturers that the code had re- 
sulted in immeasurable good to them. As proof of their desire to continue the 
benefits accrued to them under the code, they entered into a voluntary ag- 
reement to perpetuate these benefits. This voluntary agreement is now in 
effect in the industry. 

The weak features of the ISA administration were the delays in getting 
action from the administration on important matters confronting the industry. 
After a hearing in Washington, it sometimes took months before an amendment 
would be passed by all of the boards and approved by the administration. We 
realize that a great deal of this delay might have been due to the doubt felt 
about the constitutionality of the law, but we do believe that by transferr- 
ing the industry from one division to another, and from one deputy to an- 
other, caused considerable delay. It took time for a new administrator to be- 
come thoroughly acquainted with the intimate problems of the industry al- 
ready understood by the former administrator, because he not only knew the 
important problems of the industry, but also knew the temperament of im- 
portant members of the industry, and had succeeded in gaining their confi- 
dence. . i 

The strongest feature of the NBA administration was the fact that every 
member of the industry, n> matter how large or small, or wherever located in 
the country, was governed by the code for the industry. 

Under a voluntary agreement, there is no compulsion to join, and since 
the agreement is only enforceable against the se who do assent, no voluntary 
agreement can ever become effective in any industry. It is only a matter of 
time when those who have not assented to the agreement will chisel to such 
an extent that will make it impossible for those who have assented to meet 
their competition. Feeling the loss in sales volume, they want to be free 'to 
compete, even if they have to engage in the same practices which eventually 
destroy their chances of making a profit. Another weakness of the NBA, was 
the varying conditions in closely related codes. Labor provisions should have 
been uniform, so that one code would not offer more favorable conditions than 
another, causing manufacturers to fight to remain under more favorable ones. 

The Code Authority consistently refused every request for exceptions to 
or exemptions from the labor provisions or the trade practice rules of the 
code. In every case, the investigations proved that the requests made by 
manufacturers were not intended to equalize conditions for them, but to ob- 
tain some advantages over other manufacturers. Geographical locations are no 
disadvantage in the handbag industry, since they are offset by other advan- 
tages, such as the difference in labor costs. Experienced workers in New 
York are paid two and one half times as much as are workers recruited loc- 
ally in other cities, and since machinery and methods are used extensively to 
do the operations formerly performed by skilled workers, no efficiently op- 
erated factory is handicapped by being located in any other part of the 
country. The advantage of catering more intensely to local markets offsets 
any added costs in freight and cartage of raw materials from eastern factories* 

In refusing any exceptions to or exemptions from the code, it was poss- 
ible to check compliance more easily. It is much more difficult to detect 
violators of the code when exceptions are granted for one reason or another. 

9811 



. -229- 

At the beginning of the code, about 40fo of the manufacturers thought 
they were entitled to exceptions; 1 ater, very few ra?de requests after 
being assured that no one in the industry could obtain any exceptions 
that might give them any advantages. A most persistent member of the 
industry with a factory located in the west, submitted legal arguments 
and briefs for an exception to the wage provisions, which the Code 
Authority was able to prove to the administration, would have put this 
firm in an advantageous position over all other members of the industry. 

In general, it was found that every manufacturer located his factory 
in a particular section of the country because he felt it was an advantage 
for him to do so, and that he was fully compensated for any disadvantages 
for which he claimed exceptions or exemptions. 



9811 



-230- 



EXHIBIT H 
Brief on Di'tec'ou.nts 



9811 



-231- 

Prior to the year 1929, the nanufacturers of ladies' handbags had, 
for more than fifty jrears, sold their goods on terns of 2/10/60 or 
3/l0/eom. 

From 1930 up to "larch 25, 1934, the tine the code for the industry 
became effective, the discount in the industry varied fron 3p to 8,c 
The code fixed the maximum terns for the industry at not in excess of 
3/lO/oom. These terns were accented "by all retailers throughout the 
country. Since Hay 27, 1935, when the codes became inoperative, the 
terms in the industry h.-'ve remained at 3/lO/eon. A-fe^ large retailers 
and chain stores have denmded that the nanufacturers fix the disco unt 
at 3/10/eom. 

In the year 1929, the sales volume for the industry amounted to 
abotit 70 million dollr.rs. Using the 1929 figures as a basis, the sales 
volume for the year 1930 decreased a-onro::iraately 30,: ?,. 40^ in 1931, 60,o 
in 1932, 55$ in 1935, and about 50;j in 1934. This slump in sales 
volume presented a very serious situation to nanuf acfcurers who had an 
overhead exoense based on large sales volume. It was> impossible for 
them to readjust the overhead to the rapid decrease in their spies. A 
few nanuf p.cturers , because of the necessity for their maintaining sales 
volume, entered into an agreement with some large retailers to give then 
a rebate on all their ou^chases ,' in consideration for which these 
manufacturerf-- "ere promised /by such retailers that they rrould be made 
preferred sources. The few manufacturers 'mho agreed to this arrangement, 
expected thru this means to take the business away from competitors .who 
were not similarly favored by such retailers. The proposition of re- 
bating ho.ving been accented "'oy a few nanufacturers, the retailers con- 
tinued to offer the proposition to other nanuf acturers, many o" whom 
having already found thenselves unable to obtain an;/ business fron 
these retailers, did not hesitate to accept their proposition. Those 
who accepted late, were required to pay a larger rebate. It was not 
long before the manufacturers were competing on the amount of rebate 
they would give. This rebate final!]'' reached 5'j. 

3y this time, the retailers were getting rebates from so many 
manufacturers it was no longer a secret, not was it termed a rebate. 
It was added to the regular cash discount of 3p, and the discount be- 
came S'?, Hiich eventually most of the manufacturers ^ere coerced into 
giving, if they ^anted to do business with these retailers, the result 
being that certain large retailers and clip in stores were receiving a 
discount of 8?, '-'hile small retailers continued to receive fron the 
same mpnuf acturers only the r <S)o cash discount. 

Within the past ten years, retailers have standardized retail 
prices of handbags so as to avoid stocking too large an inventory at too 
many different nrices. To conform with this policy, the retailers 
throughout the country fined the retail nrices of handbags at 50rf, $1.00, 
$1.95, S2.95, $4.95, ;'o7.50 and upwards." These nrices becane so 
standard that any in-between nrice is regarded as an unusual price, 
or sale Drice, used mainly to denote a mark down from the regular 
or standard prices. T/hen the retail nrices were standardized by the 
retailers, it eventually followed that the wholesale nrices became 
standardized, "oy the retailer demanding that the manufacturers price 

9811 



-232- 

their lines to correspond with the standard retail prices, that would 
give the retailer r percentage of -profit sufficient to cover the re- 
tailer's overhead and a. -profit on his sales. The retailers demanded 
that the manufacturers >rice their Tines as follows: 

$3.?5 a dozen to retr.il at 50rf 



7.50 " 


ii 


it 


ti 


n 


$1.00 


15.00 " 


ii 


ii 


ii 


ii 


1.95 


21.35 " 


n 


ii 


ii 


n 


2.95 


rziZ i "• r~ It 


ii 


n 


ii 


ii 


4.95 


54.00 » 


ii 


ii 


n 


ii 


7.50 


72.00 " 


ii 


ii 


ii 


ii 


10.00 



It followed, however, that -If retailers pre not billing to pay 
the same wholesale prices to the nanuf acturers , and mrice concessions 
are continually sought by retailers, so as to allow them a larger per- 
centage of profit. 

TTith the r-holes-le mrice line's standardised, the manufacturers are 
forced to compete on a basis of style, quality and value. Comoetition 
amongst the manufacturers is very keen. Each manufacturer striving to 
create new styles and by giving iaore value, he hones to attract business 
away from his competitors. Style is an important factor, rid each year 
the urnuf acturers' representatives are sent to Europe to search the 
markets for new ideas. A style hag rarely remains in r 'manufacturer's 
line more than eight to ten weeks. Then it must be replaced by a new 
style becaii.se of change in color, laterial, or because the style is 
copied by a maker of cheap handbags. Very frequently, a style produced 
in an expensive bag is copied into a cheep bag soon after it is shown 
in the shop of a retailer. 

There cannot be any price fining by the manufacturers of handbags, 
since there are no standards of value, materials or workmanship that are 
required in each wrice line, and since no two manufactuers make the 
identical bags. The margin between the manufacturer's costs and bis 
selling price is so narrow that n grert many of the oldest and most 
substantial firms in the business have been unable to onerate and have 
been forced into involuntary retirement. Uith twice the number of 
manufacturers competing for one-half the normal volume of business, 
competition has placed the handbag business at the mercy of the retailers. 
Because of these conditions,! the retailer is now demanding concessions 
in price, extra dating, higher discounts, and added services. 

The Z/o discount 'all owe by the manufacturers is a cash discount, 
and is offered as an inducement for the prompt payment of the invoice on 
the due date, which in this case is on the tenth dav of the month 
following the date of shipment. In anticipation of receiving payment 
of the major mortion of their accounts receivable on the tenth day of 
each Month, it is the custom for the manufacturers in the industry to 
arrange terns with their sources of supplies that, will enable them 
to pay their current indebtedness of the fifteenth da} r of each month. 
This arrangement allows the manufacturers five days for the receiwt of 
their funds. Since the ca.sh discount the manufacturer is allowed defends 
upon the payment of his bills promptly on the fifteenth of the month, 

9811 



-233- 

the nanuf aeturers , particularly the small manufacturers with limited 
caoital, and with little or with no borrowing capacity, are -rilling to 
rllo" the 3,i discount in order to collect their outstanding accounts 
promptly, and enable then to maintain their oim credit and to earn 
the cash discount allowed then for laynent on the due date. 

The provision of the code prohibiting the giving of terns in 
excess of 3/10 eon was also intended to orevent large manufacturers 
who were financially able, from granting end of the month dating on all 
shipments made on the rfter the twenty- f if th of the previous month. 
3y this leans of granting lon;er dating, these large manufacturers had 
m advantage that Could be used against the small manufacturer with 
limited capital, whb "ould be unable to operate if he had to grant 
the extra 30 days on shi :ments made after the twenty-fif th of the 
month. It would also beco ie the -practice for retailer to have their 
shipments made whenever possible, on or after the twenty-fifth of the 
month, so as to take advanta ;e of the extra 30 da~~s it allowed them. 

Some manufacturers in the industry are financially able to return 
every remittance received after the due date, if the full amount of 
cash discount is deducted. Others alio- the deduction of a smaller 
discount than 3> based on the number of days payment is made past the 
due date. Some manufacturers are in such urgent need of funds they 
cannot afford to return or hold the check mending an adjustment of 
the discount-, erroneously deducted. They denosit the check and tr T /- to 
collect the unearned portion of the discount. 

During the code, there were many cases where retailers demanded 
of p manufacturer that he secretly allor- first of the month dating and 
even longer dating, pad '-'lien granted, it Was used by the retailer to 
earn extra anticipation. Hot more than 20 of the manufacturers in the 
industry p.re financially able to grant terms beyond the tenth of the 
month, without seriously affecting their ability to 3ta ,r in business. 
Prior to the code, the manufacturers were lax in permitting delinquents 
to deduct the cash discount after the due date of the invoice. Hot more 
than 40$ of accounts receivable were maid promptly on the due date, 
(the tenth of the month.) The code rule required prompt payments from 
the retailer to entitle him to deduct the cash discount. The manu- 
facturers reported at that time that as a results of this code rule, 
more than 80'n of their accounts receivable were paid t>romptly on the 
tenth day of each month. 

In calculating costs, the manufacturer does not include the 3n 
cash discount in the cost of the article. The cash discount is figured 
as a deduction from income* 8)i discount could not be considered a 
legitimate cash discount. The extra 5,6 demanded by the retailer is 
definitely a trade discount and it must be included in the cost. In 
demanding rn extra 5;o discount, the retailer is really chiselling on 
the orice. If this is -hat is desired, he might try to get price re- 
duction from individual manufacturers, since 23rices are not fixed in 
the industry, and each manufacturer is at liberty to make any price 
concessions to pny buyer for any reason .he thinks warrants such con- 
cessions. It night require the retailer to bargain individually with 
each manufacturer for prices, and for that reason he prefers to force 

9811 



-234- 

the granting of S'.o discount on the entire industry. It is certain 
that if the large manufacturers agree to alio" the 3',o discount, the 
small manufacturers will be restrained from doing business with such 
retailers unless they also agree to grant them the 8 L ,.> discount. 

The nanufacturers earn on the average, discounts of only 1 on 
their sales volume. T/heh they allot? 3y for prompt payment within an 
average 30 days, it is allowing the retailer at the rate of 35y a year. 
In demanding a cash discount of 8,j from the industry! the retailer is 
asking a rate of 96p a year for prompt payment. The discount of 3y 
granted by the industr- is a. cash discount, and a cash discount is a 
deduction of the selling jrice, and it jecomes a tra.de discount, and 
because it is a trade discount, it is an element of nrice. It has never 
been the custom in the ladies' handbag industry thru its entire 
existence to ever alio 1 ; trade discounts. 

Some retailers in demanding this trade discount of 5fb, give as their 
reason that the extra 5;& discoiuit is required as a " CUSHI CC.7" or a. 
"SlDDEElT PI.OxIT" , to insure them a >rofit, when and if, they fail to 
earn a net profit on ;• normal mark urn, which thOy add to the wholesale 
cost of the handbag when the orice to the consuier is fixed. In other 
i-'ords, they demand that the ".a-nufacturer subsidize them for selling 
handbags. The manufacturers cannot understand why they should be 
nado to subsidise the retadler just because they have used all of their 
ingenuity and probably risked al] o" their caoital to construct the 
hind of handbags that the retailer must have to sel 1 the consuier. 

The records shov that the nanufacturers of handbags rarely make 
a profit of ';>)o on their sades. !7han the retailer demands the extra 
5/S discount, the :man\xfacturer is compelled to seek some other means of 
providing for this additional 5',o since to give it out of his profits 
would irine out his entire profit. If he includes fhe 5 into his costs, 
he will be discriminating against the small arid medium, sized retailers, 
"horn he soils at the 3;o discount, - T ho rill be paying him an extra profit 
of 5yo that he has added to his costs, but has given back to the large 
retailer. 

Before the code, the nanufp.cturers too frequently granted the 
extra. 5,: discount to the retailer, at the exnense of the sadesnan, who 
was asked to give up part of his commission, and at the exoense of 
his workers, who were required to work for less wages, or accent a 
lower piece work r-te under threat of having the factory closed down, 
because of inability to procure 'orders at competitive mrices. 

Cert; iii retail groups are members of an association whose members 
have a, combined purchasing power of handbags equal to about one-third 
of the total outp\it of the handbag industry. The members of this 
association are refusing to 'nry fro ; those manufacturers who will not 
grant them the 3y discount. 

If the industry is unable to maintain a uniform cash discount 
for all members of the industry, the trade practice rules will become 
ineffective and •unenforceable since no majiufactuer who has assented 
to this agreement covild long "ithstand the refusal of lar^e retailers 
to buy from him because he refuses to sell on terms in excess of 

9811 



-235- 

3/lO/eon, while other manufacturers who have not assented to the 
agreement are doing so. 

If the industry, thru its voluntary agreement, cannot establish 
and enforce maximum terns of sale for all members of the industry, 
competition -'ill be based again on the lowest labor costs, resulting 
in the complete break down of the minimum wages and .maximum hours and 
prohibition against child labor rules established for the industry. 



9811 



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EXHIBIT "J" 



Letter outlining policy respecting Classification 



9811 



-237- 
EXHIBIT J. 



November 15, 1933 



Mr. Maurice S. Mosesson 

Associated Handbag Industries of America 

303 Fifth Avenue 

Hew York, New York 

Dear Mr. Mosesson: 

I promised today to secure for the members of your industry an 
interpretation of the policy of this Administration as regards classified 
wage rates, and in particular an interpretation of the phrase "basing 
rates". 

The Administration will not in the future approve Codes of Fair 
Competition containing union agreements or classified wage scales. It 
will, however, approve codes containing two or three basing rates. Such 
basing rates are to be in no way confused with the so-called "classified" 
rates. The term "basic rates" may best be explained by an example. 
'There there exists a clear, well-defined and logical separation of employ- 
ees in an industry into two or three groups, a basic wage may be set for 
each group. Thus, in the steel industry, for example, there is a very 
sharp line of demarcation between skilled and unskilled labor. If you 
will remember, in our conference last Friday, I suggested that it might 
be possible to set one minimum wage for manufacturing employees and a 
another minimum for non-manufacturing employees. The difficulty of such 
a proposal became at once apparent, however. Someone else, Mr. Waldraan 
I believe, suggested that the line be drawn according to skill or length 
of time employed. The term "skilled", however, is one very difficult 
to define and the length of service is by no means an adequate criterion. 

So far as I am able to judge, there is no clear basis on which a 
basic rate above the minimum may be fixed in vour industry. There does 
not exist in this industry any such clear separation of employees into 
groups as there does, for instance, in the steel industry. Should the 
Ladies' Handbag Industry desire to set a basic rate above the minimum, 
it might be done by some such plan as this: The minimum might be defined 
to apply to the so-called non-manufacturing employees and the two or 
three types of manufacturing employees who customarily receive the lowest 
wages paid in the industry. Following that basic rate might be provided 
for manufacturing employees, except for those employees as are already 
included in the above group. I think such a plan might be workable. 

I hope that I have clearly set forth the policy of the Administration 
in this matter. I urge you to complete the negotiations on this code as 
quickly as possible. I should like to set a date for hearing sometime 
this week - at the very latest, next week. 

I appreciate your cooperation in the past and anticipate your 
continued cooperation in the future. 

Very truly yours, 

. James C. Worthy, Assistant Deputy Administrator, 

jcw/g 

CC sent to Schlesigner and Waldman 
9811 



-2o8- 



E : X H'l.l T T K 
Reports on definition of Semi. -Ski ] lod 



9811 



-239- ■ 

EXHIBIT K 

LADIES H ANDBA G INDUSTRY. CODE AUTHORIT Y 

REPORT OF THE COMHTTSE ON DEFINITION 
OF SEMI-SKILLED 

(Article IV, paragraph 2) 

The Committee met on Saturday, April 21 from 10 to 2 F. M. 

The Committee met on Saturday, April 28th, from 9:30 to 3 B.M. 

The Committee met on Monday, April 30th, from 10 A.M. to 4 P.M. 

The last two meetings were attended by the Administration member. 

The following is the final report of the Committee. 

ARTICLE A. The Definition of Semi-Skilled in Cutting . 

(1) All cutting dpefatrdn's*; e«;efting^ip , er, wadding^Jtd rubber 
cloth cutting are to be considered semi-skil jed. Thjpfollowing members 
of the Committee are in favor of this definitions'-'"^ 

I . Schoenholz 
Chas. Wolf 
S. Maksik. 
A. G-reenbaum 

(2) The following members voted against the above and propose 
the following: 

J. Margolian 
R. Bur stein 
S. Goldsmith 

The only employees in the Cutting Department that shall have the 
rating of semi-skilled shall be employees engaged in the cutting of 
outsides, with the exceptions of handles, handle linings, pullers, 
puller linings and gussetts that are cut by clickers. Also any em- 
ployees engaged in the cutting of silk linings by knife are semi-skilled. 

(3) Mr. Lubliner objects to the two foregoing definitions and 
offers the following: 

All employees engaged in cutting shall be considered semi-skilled 
workers . 

ARTICLE B. The Definition of Semi-Skilled ip Operating . 



( l) All outside operating shall be con^dered;$$Hn'i-skilled except 
handles. Linings as the Code provides. The following recommend this 
definition: 



-240- 

I . Schoenholz 
Chas. Wolf . 
S. Mnksik 
A. Greenbaum 

(2) The only employees engaged in the Operating Department that 
shall he rated as semi-skilled workers are those who are engaged in 
sewing welded, bottoms and gussetts, pocketbook gussetts, sewing leather 
and lining together, without a gauge on out sides. 

The following propose this definition: 

J. Margolian 
H. Burstein 
S. Goldsmith 

(3) Mr. Lubliner objects to the foregoing definitions and offers 
the following: 

All employees engaged in operating shall be considered semi-skilled, 
except as limited by the Code. 






ARTICLE C. Definition of Semi-5kil led in Framing 

(l) All framing shall be considered semi-skilled, excepting all 
purses not attached to frames. 

The following members of the Committee are in favor of this 
definition: 

I . Schoenholz 
Chas. Wolf 
S. Maksik 
A. Greenbaum 

(?) The only employees in the Framing Department who shall be 
rated as semi-skilled workers are those who can frame completely an 
inverted or inner-grip frame or who participate in framing of covered 
frames, full inlay frames or shell frames. 

This does not include the inside pockets of any of the above 
frames. Also purse framers shall not be rated as semi-skilled workers, 

J. Margolin 
H. Burstein 
S. Goldsmith 

(3) Mr. Lubliner objects to the foregoing definitions and offers 
the following: 

All employees engaged in framing shall be considered semi-skilled 
workers . 



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A2.TICLE D. Definition of Semi- Skille d in Taring. 

(also known as Skiving) 

(1) All employees engaged in paring (meaning sometimes "skiving") 
shall "be considered semi-skilled. 

I. Schoenholz 
Chas. Wolf 
S. Hates ik 

A. Greenbaum 
P. Lubliner 

(2) A semi-skilled parer is one who can pare all types of work 
and who understands the paring machine so as to he ahle to make the 
necessary changes of gauge, knife and emery wheel. 

J. Llargolin 

H. Durs te in 
S. Goldsmith 

ART I CLH . Definition of Sem i- Skilled in Pockethook Making 

(1) All employees engaged in pockethook making are considered 
semi-skilled, except turning in handles, tucks or loops and all table 
work on linings. 

I. Schoenholz 
Chas. Wolf 
S. i.Iaksik 
A. Greenbaum 

(2) A semi-skilled pockethook maker is one who turns in leather 
and assembles a bag. 

J. Llargolin 
H. Burstein 
S. Goldsmith 

(0) l.Ir. Lubliner objects to the two foregoing definitions and 
proposes the following: 

All employees engaged in pockethook making shall be considered 
semi-skilled workers. 

ARTICLE j? 

The Committee agree that no person shall be considered semi-skilled 
on any of the above operations unless he has been employed on any opera- 
tion for a period of six months. 

(1) The following vote for the six 'months period. 

I. Schoenholz 
Chas. Wolf 
S. i.iaksik 
9811 A. Greenbaum 



-242- 

(2) The following vote for nine months: 

J. Margolin 
II, Eurrtein 
S. Goldsmith 

(5) iir, lubliner votes for three months. 

Messrs. Margolin, Goldsmith and Burstein object to Mr. Lubliner 1 s 
right to vote on this committee. 



I. Schoenholz 

Chairman of the Committee 



9811 



' ' "-243- 

CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

303 Fifth Avenue 

New York 

May 1st, 1934 



Dr. Earl Dean Howard 
Deputy Administrator 
Commerce 31dg. 
Washington, D. C. 

Dear Dr. Howard :- 

I am enclosing a report of tne findings of the Committee on the De- 
finition of semi-skilled workers; also a copy of the verbatim report 
dictated by Dr. Paul Abelson, who was present at this last meeting. 

From the report of the vote, it must be evident to you that the same 
division of interests dominated these meetings - the out-of-town 
against New York - only in this instance, the deciding vote in favor 
of the adoption of the report was given by a manufacturer who has a 
factory in New York as well as out-of-town, but who opposed the efforts 
of the out-of-town manufacturers to minimize the class of unskilled 
workers to a point where it would be neglible. 

I pointed out to the Committee that very little was required to be 
added to the exemptio-ns already stated in the Code in order to give them 
the Definition of a Semi-Skilled Worker. I regret that the Definitions 
that were adopted, even by the majority, are lengthy and that it will 
be almost impossible for a Code Director to obtain compliance unless 
he spends considerable time in each factory to watch the operations of 
the workers. However, these Definitions are the best that could be ob- 
tained under the existing conditions. 

Yours very truly, 



(Signed) A. Mittenthal 
Code Director 
Ladies' Handbag Industry 



A. Mittenthal/TD 



QR11 



-244- 

CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

303 FIFTH AVENUE 

NEW YORK 

May 1st, 1934. 

A final meeting of the Committee appointed by the Code Authority 
of the Ladies' Handbag Industry to define a semi-skilled worker was 
held on April 30, 1934, at the McAlpin Hotel. The members of the Com- 
mittee present were: 

I . Schoenholz 

C. Wolf 

S. Maksik 

A. Greenbaum 

J. Margolin 

K. Burstein 

S. Goldsmith 

Dr. Paul Abelson - Administration Member 

Fhilip Lubliner - Labor Member 

A. Mittenthal - Code Director 

The Committee by a vote of 4 to 3 adopted the following report 
defining a semi-skilled worker. Those members voting for the report 
were : 

I. Schoenholz 

C. Wolf 

S. Maksik 

A. Greenbnum 

Those members voting against the report were: 

J. Margolin 
S. Burstein 
S. Goldsmith 

The minority report is herewith attached; also dissenting opinion 
of Fhilip Lubliner, Labor Member on the Committee. 

ARTICLE A. Th e Definition of Semi-Skilled in Cutting . 

All cutting operations, excepting the cutting of paper, wadding 
and rubber cloth are considered semi-skilled. 

ARTICLE B. The Definition of Semi-Skilled in Operatin g. 

All outside operating shall be considered semi-skilled excepting 
handles and linings as provided for in Article 4 - Section 2 of the 
Code. 

9811 



-245- 

■ CODE AUTHORITY 
LADIES' EMBAG IIIDUSTEY 

303 FIETH AVEEUE 
HEW YORK 



Hay 1st, 1934 



."IEORITY REPORT 



ARTICLE A - The Definition of Semi-S1-.illed in Cutting 

The only employees in the Cutting Dept. that shall have the rating 
send -skilled shall be employees engaged in the cutting of the out sides, 
with the exception of handles, handle linings and gussetts that are cut 
by clickers. Also any employees engaged in the cutting of silk linings 
by knife are semi-skilled. 

ARTICLE 3 - The Definition of Semi -Ski lied in Operating 



The only employees engaged in the Operating Department that shall 
be rated as semi-skilled workers are those who are engaged in sewing 
welded bottoms and gussetts, -oocketbook ;ussetts, sewing leather and 
lining together, either on a high or flat machine, sewing fancy stitch- 
ing without a gauge on out sides. 

ARTICLE C - The Definition of Semi -Skilled in Framing 

Tue only employees in the Framing Department who shall be rated as 
semi-skilled workers are those who can frame completely an inverted or 
inner-grip frame or who participate in framing of covered frames, full 
inlay frames or shell frames. This does not include the inside pockets 
of any of the above frames. Also purse framers shall not be rated as 
semi-skilled workers. 

ARTICLE D - The Definition of Semi -Skilled in Parine 



A semi-skilled parer is one who : can pare all types of work and who 
understands the taring machine so as to be able to make the necessary 
changes of gauge, knife and emery wheel. 

ARTICLE E - The Definition of Semi -Ski lied in Pocketbook Making 

A semi-skilled pocketbook maker is one who turns in leather and 
assembles the bag. 

ARTICLE F 

The Committee agrees that no person shall be considered semi-skilled 
on any of the above operations unless he has been employed in px'iy 
operation for a -oeriod of nine months. 

9811 



-246- 

RSPORT OF PHILIP LUELIHER, LABOR MEMBER OF THE CODE AUTHORITY, 
AND iEEOEE OF THE SIB-CCUi.ITTEE, TO DEFILE THE PROVISIONS DEAL- 
ING "JITH WAGES FOP. THE SEMI -SKILLED 



In submitting my report on the definition of the term of semi- 
skilled employees, I want to state that Article IV, Paragraph 2, pro- 
viding: "Ho serai-skilled employee engaged in the cutting, framing, 
paring, po eke tbo ok-making end operating (except lining operators, cement- 
ing or casting) employed in the manufacture of any of the products covered 
by the provision of this code, made of any materials other than imitation 
leather, shall be paid at less than 45^ per hour" , is self-explanatory. 

For many years all the manufacturers, collectively and individually, 
considered the operations of cutting, operating, pocket bo ok-making, 
framing and -oaring as skilled oper tions. It is true that there were 
two classes agreed upon, a first-class and also a second-class which 
differentiated between an accomplished worker who could do everything, 
and a, worker who could perform only certain parts of the operation. 

In the co.se of pocket bo ok-making, a class of semi-skilled workers 
was recognized, such as the helpers who are the direct assistants to the 
pocketbook makers, and these helpers received a wage as high as $31.00 
per week, and today they receive $23.30 for 40 hours' work. 

The provision in the code establishing a semi-skilled employee in 
the above mentioned branches of the industry was intended as a concession 
to cover the special conditions in those factories that are outside of 
the metropolitan district of New York City, where a system of sectional- 
izing the work has been installed. The workers in the out-of-town' locali- 
ties are broken in to certain operations and within a very short period, 
after being steadily engaged in that particular operation, become very 
efficient and will compare most favorable in speed and efficiency on 
that operation with any skilled worker. It is for this reason that the 
term of semi-skilled employee is allowed in our code, and by excluding 
cementing, pasting and lining operating, the obvious intention of this 
provision of the code is to cover all workers, except those who are un- 
skilled, who are engaged in the making of pocketbooks. The only 
question to be determined is: when is a new worker coming into the 
trade as an apprentice and engaged in pocketbook-making, framing, 
cutting, operating or -oaring, to be considered semi-skilled? 

Our answer to this question is that a maximum of three months * 
experience is necessary to be regarded , as a semi-skilled worker in the 
industry within the meaning of the code. 

To define "semi-skilled", as the committee defines it, is to 
nullify the intent of the provision of the code and to render the en- 
forcement and compliance of the provision totally impossible. 

The definitions contained in the reports of the majority and the 
minority of the committee are unsound as I shall presently show. 



9311 



-247- 

First: Cutting: The definition of the majority, excluding paper 
wadding and rubber-cloth cutting fron the semi-skilled provision is 

wrong. i T o manufacturer will trust any learner to cut any materials, 
whether it be outsides (that is leather, silk, etc), or linings, or 
paoer, or wadding, unless the cutter has experience, since it requires 
precision, knowledge of materials and skill in handling a shear-cutting 
or clicking machine to do this work. Host of the manufacturers in en- 
gaging cutters, even in the out-of-town areas, try to ™et workers that 
have experience in handling machines. They get either shoe-cutters, 
cutters fron bookbinderies or other kindred industries, and it takes a 
very short time for this kind of worker to adapt himself to the handbag 
line. If a manufacturer should, take an altogether inexperienced worker 
to work at the machine, he will find that it will take time and appli- 
cation before the worker will be able to cut satisfactorily even the 
above mentioned items, such as paoer, wadding and rubber cloth. 

Second: The definition of the minority which excludes handle 
linings, pullers, puller linings and gussets that are cut by clickers, 
is a definition that would ".lace 50;j of the cutting branch of the in- 
dustry in the unskilled branch. The cutting branch of our industry is 
conceded by all manufacturers as being' the foundation of a factory. A 
cutter has to handle a knife, work at a hazardous clicking machine or 
shear-cutting machine, and must be constantly on the lookout to save 
and economize on trie materials. 

Definition of Operating : Any attempt to take part the various opera- 
tions in operating is, to my mine, a pure evasion of the provision of 
the code. If we are to consider the definition of semi-skilled as pro- 
posed, it would make it impossible for the majority of the operators to 
receive the benefit of the 45/j per hour. In considering this provision 
of the Code, after considerable debate, the only exclusion conceded was 
lining operating. If other operating was to be excluded, it was 
strange that there should have been a limitation on linings; and even 
on linings there are certain o-oerations, such as ruffle-pockets, sewing 
on of pipings, etc. that are highly skilled. 

Definition of Framing : In its attempt to exclude purse framing 
from the semi-skilled, it would put bag-framing, which is one of the 
highest paid and most skillful operations in our industry on the lowest 
level. ITo beginners can frame a purse unless he is broken in and works 
at it constantly for a number of weeks, and even though there are labor 
saving devices and machines which have lately been introduced for 
f raining purposes, it would still necessitate hard application and stead;' 
practice before a worker can frame a purse properly. It is my opinion 
that there are no unskilled workers in the framing branch altogether, 
that all the work performed on framing is skilled. It certainly cannot 
be defined as less than semi-skilled. We object against this proposed 
definition as tending to break down the standards of a branch of the 
industry that has for many years been fairly well paid. 

Definition of Pocketbook-making : The definition of semi-skilled 
on pocketbook-making as made by the majority as well as the minority, 
is confusing and it will make it altogether impossible to enforce com- 
pliance. A semi-skilled worker in the pocketbook branch of the industry 

9811 



-248- 

is essentially the one that can do turning-in or assembling, whether 
on sill:, leather, or any other hind of material. Since the work of 
pocketbook-making is so sectionalized that every worker performing his 
particular ; rt is skillful and efficient, there is no reason to deprive 
these workers of the right of 'earning 45{£ per hour. 

Unless the definition of semi-skilled is as suggested in my report, 
there will be no adequate wage provision to prevent unfair competition. 



(Signed) Philip Lubliner 



-249- 

code authority 

ladies' eaedeac- industry 

303 fifth avehue 

1137 YORK 

May 1st, 1934 - 

ARTICLE C. The Definition of Semi -Shi lied in Eraming 

All framing shall be considered semi-skilled excepting the framing 
of purses not attached to frames. 

ARTICLE D. The Definition of Semi -Skilled in Paring 

All employees engaged in paring shall "be considered semi-skilled. 
This definition was also voted for "by P. Lubliner in addition to the 
four Industry members already recorded. 

ARTICLE E. The Definition of Semi -Skilled in Pockefbooh Making 

All employees engaged in pockefbook making are considered semi- 
skilled except turning in handles, tucks or loops and all table work 
on linings. 

ARTICLE E. 

The Committee agrees that no person shall be considered semi- 
skilled on any of the above operations unless he has "been employed on 
any operation for a period of six months. 



9811 



-250- 
ITATIOEAL RECOVERY ADMI1TI STRATI OH 



May 3, 1934 



MEMORANDUM 



TO: Mr. Rosenblatt 

FROM: Earl Dean Howard 

SU3JECT: Definition of semi -ski 11 eel in Ladies Handbag Code. 

Attached hereto is the report of the Committee on the Definition 
of semi-skilled workers in the Handbag Industry. In pursuance of 
the agreement reach with Colonel Lea, Mr. McGrady and yourself, a 
date will be set for hearing on this definition. 

Inasmuch as the question of representation will be presented 
as soon as the minority members of the Code Authority have forwarded 
such a resolution to us. I think the date of hearing on the defini- 
tion should be held open until \/e have both subjects to consider at 
the spme time. 



(Signed) Earl Dean Howard 

Earl Dean Howard 
Deputy Administrator 



9811 



-251- 

code authority 

ladies' i-iaedsag ihdustey 

303 fifth avefje 

HEW YORK 



May 14, 1934 



Mr. Earl Dean Howard 
Deputy Administrator 
Commerce Bldg« 
Washington, D. C. 

Dear Dr. Howg,rd, 

At a regular meeting of the Code Authority held on May 10 
the Definition of Semi-Skilled Uorker was again presented 
for consideration. At the request of the Code Authority 
member, Mr. George Meyers, the consideration of the 
Definition of the Semi -Skilled Y/orker was postponed until 
the next regular meeting of the Code Authority for the pur- 
pose of giving our Administration Member, Mr. 0. W. Pearson, 
an opportunity to become acquainted with the industry and to 
enable him to study the purposes and the effects of the pro- 
posed definitions that are to be submitted by the majority 
and the minority reports of the committee. 

Very truly yours, 



(signed) A. Mittenthal 
Code Director 
Ladies' Eandb?„j Industry 



A' ^i t tenthal/ edl 



9811 



-252- 

NATIOITAL 3EC0VERY ADMINISTRATION 

WASHINGTON, D. C. 

45 Broadway 
Hew York City 



May 17th, 1934 



Iur. James C. Worthy 

Doom 4381 

Department of Commerce Building 

Washington, D. C. 

Dear Mr. Worthy: 

This is merely to report progress on the matter of 
the definition of semi-skilled workers in the Ladies 
Handbag Industry. 

I have visited a number of factories here in New York 
during this week and on Tuesday and Wednesday of next 
week, I am going to get time off to visit some out-of- 
town factories, as I am tol: that the processes in the 
out-of-town factories are somewhat different from those 
in hew York City. 

I wired you this morning respecting the "budget, a copy 
of which I enclose. I em at a loss to understand what 
happened to my original approval , but I cannot find any 
trace of it here in the office. If you desire it, I can 
enlarge upon these telegrams when I reach Washington, 
Saturday. 

Yours very truly, 

0; W. PEARSON 

ADI INI STRATI Oi" MEMBER 



ONP:DAR 



9811 



-253- 

June 21st, 1934. 
STATEMENT 0? LABOR 017 THE SEMI-SKILLED WORKERS 

or zee pocketsgok iitdustfy 

The undersigned , after having met in conference with the repre- 
sentative of the employers to classify and define the semi-skilled 
workers in the industry, have _,iven due consideration to the subject 
matter before them. Our conclusions, based on many years in the indus- 
try, are as follows: 

Definition of Cutting 



All cutting operations are skilled and semi-skilled operations. Four 
outstanding manufacturers of the industry have agreed in a previous 
discussion on the very same subject to the following: 

"All cutting operations, excepting paper, w.-dding and 
rubber cloth cutting, are to be considered semi-skilled." 

The following committee members have signed their names to this definition: 
I. Schoenholtz, Chas. "wolf, S. Males ih and A. G-reenbaum. 

'Je dispute the exceptions to paper wadding and rubber cloth cutting, 
and ask that they be included as skilled and semi-skilled operations. 

Definition of Operating 

All operating on outside work, linings, handles, pullers, etc., 
must be considered skilled or semi-skilled operations. 

The four above mentioned employers have gone on record with the Code 
Authority for the Ladies' Handbag Industry on the question of defining 
the semi-skilled operations in the operating branch of the trade as follows! 

"All outside operating shall be considered semi-skilled 
except handles." 

The undersigned, representatives of labor, cannot make it too 
emphatic that operators on handles have always been considered in the 
Hew York market on an equal par with all other operators, because 
operating on handles requires skill, ability, knowledge and experience. 
The handle is one of the most important parts of the entire bag. Women 
will first detect defective operating on handles. We ask that operators 
on handles be treated on an equal par with all other operators. 

The same must be said about lining operators. 

Definition of Semi -Skilled on Framing 

Our definition for labor as far as framing is concerned is as 
follows: All framing shall be considered skilled and semi-skilled. 



9 311 



-254- 

A committee of representative manufacturers consisting of 
I. Sch.oenh.oltz, Chas. Wolf, S. Maksik and 3. Greenbaum, on a previous 
occasion defined framing as follows; 

"All framing shall he considered semi-skilled excepting 
pll nurses not attached to frames. " 

Our definition for labor on semi-skilled' oper tions in pocketbook- 
making is: All workers engaged in pocketbook-making are to h e considered 
skilled and semi-skilled. 

The above mentioned four employers have defined semi-skilled 
operations in the pocketbook-maI:ing branch of the trade as follows: 

"All employees engaged in pocketbook-mpking are to 
be considered semi-skillec , except turning in 
handles, tucks or loops, ant? all table work on 
linings." 

V, r e know from our own experience, and the employers in the City of 
Hew York have always conceded that turning in handles, tucks or loons, 
also table work on linings, are skilled operations which for years have 
been performec; by skilled pocketbook makers and classified helpers 
(classified helpers have always received and are receiving today a mini- 
mum wage of no less than v 33.31 per week). 

Definition on Paring 



Our definition for labor on the paring branch of the industry is 
as follows: .All employees engaged in paring, skiving, splitting or 
edging, are skilled or to spy the least, semi-skilled operations. 

Messrs. I. Schoenholtz, Chas. Wolf, S. Maksik and A. Greenbaum, 
four of the outstanding manufacturers of our industry, have actually 
agreed to this definition. We quote from the report submitted by 
Mr. I. Schoenholtz, Chairman of the committee, to the Code Authority of 
the Ladles' Handbag Industry, to wit: 

"All employees engaged in paring (meaning sometimes 
skiving) shall be considered semi-skilled." 

The undersigned labor representatives of the committee are at a 
loss to understand why the two representatives, Messrs. Goldsmith and 
A. Greenbaum, Particularly the latter, should have gone back on the 
definition of the previous committee of four employers, of which 
Mr. A. Greenbaum was a member, and attested his name to the definitions 
of the previous report. The comir.it tee of labor on previous occasion 
was not satisfied with the definition of said committee of four 
employers which constituted the majority opinion of the employers of the 
industry, and we demand that justice be done to the skilled workers 
of the industry who, because of circumstances, have been nicknamed 
semi-skilled workers for the sole purpose of maintaining sub-standard 
conditions in many shops in the industry , and for the further purpose 
of perpetuating unfair labor competition in the trade. 

9811 



-255- 

'Je know from our own e;cperience as workers of the industry for 
over twenty years, that a cutter, operator, pocketbook maker, framer, 
■oarer, etc., after having had experience of thirty days to two months, 
considering the present modernized end efficient methods of production, 
is entitled to he classified at least as a semi-skilled worker and justi- 
fied to the minimum scale of <15ft ( per hour provided for in the Code of 
Fair Competition for the Ladies' Handbag Industry. 



(Signed) A. Stein 
(Signed) Philip Lubliner 

Representatives of Labor on the Committee 

to define the Semi -Skilled Provision of 
the Ladies' Handbag. Industry. 



9811 



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RADIOGEA H 



MACKAY RADIO 
The International System 



1934- Jun 21 PM 

W327 262 COUNT PCTNS-AS HEW YORK HI 21 424P 
DAVID BASE 

ASSISTANT DEPUTY ADIT 1 . APPAREL SECTION DEPARTMENT OP 

COMMERCE 3LDG- 

THE FOLLOWING ARE DEFINITIONS AGREED UPON JOINTLY 3Y 
INDUSTRY MEMBERS OP THE COMMISSION STOP LABOR DEFINITIONS 
EOT READ STOP 'JILL TELEGRAPH WEEN RECEIVED STOP DEFINITION 
OP SEMISKILLED IE CUTTING: ALL CUTTING OPERATIONS ABE TO 
3E CONSIDERED SEI.il SKILLED, EXCEPTING CUTTIITG PAPER, WADDING 
OR EU3EEE OR LI1TIITG CLOTH, AND EXCEPTING HANDLES, HANDLE 
LIITI1TGS, PULLER, PULLER LININGS , GUSSETS AND SI.ALL TEETHINGS 
TEAT APE CUT 3Y CLICKERS STOP DEFINITION OP OPERATING: 
ALL OPERATING IS TO 33 CONSIDERED SEMISKILLED , EXCEPTING 
LININGS, HANDLES AND PULLERS, SEWING A1TD SEWING OH OP HANDLES 
AND PULLERS, AND SEWING IN LININGS INTO THE SAGS FOR FRAME 
PURPOSES. STOP. DEFINITION OF SEMISKILLED III POCKET300K 
i'AETEG: ALL WORKERS ENGAGED IN P0CKET300K LIAKING 3Y HAND, 
ARE CONSIDERED SEMISKILLED, EXCEPT TURNING IN HANDLES, TUCKS, 
LOOPS OR GUSSETS, OR HANGING ON FLAPS, ALSO EXCEPTING ALL TABLE 
WORK ON LININGS. STOP. DEFINITION CF SEMISKILLED IN FRAMING: 
ALL FRAMING SHALL 3E CONSIDERED SEMISKILLED EXCEPTING ALL 
PURSES AND FRAME POCKETS. STOP. DEFINITION OF SEMISKILLED 
IN PARING: ALL WORKERS WHO DO PARING ON PARING MACHINES WHO 
ARE CAPABLE OF MAKING THE "NECESSARY CHANGES OF GAUGE, KNIFE 
AND EMERY WHEEL ON A PARING MACHINE SHALL 3E CONSIDERED 
SEMISKILLED EXCEPTING THOSE WHO PARE HANDLES, TUCKS AND 
GUSSETS. STOP. TEE COMMITTEE AGREES TEAT NO PERSON SHALL BE 
CONSIDERED SEMISKILLED OH ANY OF THE ABOVE OPERATIONS UNLESS 
HE HAS 3SEN EMPLOYED ON ANY OPERATION FOR A PEP.IOD OF SIX 
MONTHS STOP- 

A MIJTENTHAL CODE DIRECTOR LADIES HANDBAG INDUSTRY 



9611 



-257- 

defiei ticks o? semi-skilled uohkers agreed upoit by both 

IIIDUSTHY EEPP-SSEITTATIVES 0? TEE COMMISSIOH APPOIilTED TO 
DEFIHE SEMI-SKILLED WOBKER 



DEEIKIT I CK OF SK I -S K ILLED I" CUTTIKG • 

All cutting operations are to "be considered semi-skilled, excepting 
cutting naper, wadding or rubber or lining cloth, and -excepting handles, 
handle linings, puller, puller linings, gussets and small trimmings that 
are cut ~oy clickers. 

DEEIUITIOK OE CPEEaTIKG 

All operating is to be considered semi-skilled, excepting linings, 
handles and pullers, sewing and sewing on of handles and -oullers, 
and sewing in linings into the bags for frame purposes. 

* * * 

DEEIKITICK SE SEMI-SKILLED IE P0CKETB00K MAKING 

All workers engaged in pocketbook making by hand, are considered semi- 
skilled, except turning in handles, tucks, loops or gussets, or hanging 
on flaps, also excepting all table work on linings. 

* * * 

DEEIEITIOE OE SEMI-SKILLED III K5AMIKG 

All framing shall be considered semi-skilled excepting all purses and 

frame pockets. 

* * * 

DEEIEITIOE OE SEMI-SKILLED IE PARING 

All workers who do paring on paring machines who are capable of making 
the necessary changes of gauge, knife and emery wheel on a paring machine 
shall be considered semi-skilled excepting those who pare handles, tucks 

and gussets. 

* * * 

The Committee agrees that no -person shall be considered semi-skilled 
on airy of the above operations unless he has been employed on any 
operation for a period of six months. 



9311 



-258- 
07DER 
CODE OF FAIR COMPETITION 

FOE THE 

LADIES' HANDBAG- INDUSTRY 

Appointing special commission to study labor conditions in the 
Ladies' Handbag Industry. 

A Code of Fair Competition for the Ladies' Handbag Industry having 
been heretofore approved on I.iarch 14, 1934, and it being provided in 
Section 2 of Article IY of said Code, that "no semi-skilled employees 
engaged in cutting, framing, paring, pocket do oh making and/or operating 
(e::cept lining, operating, cementing and/or basting) employed in the 
manufacture of any of the products governed by the provisions of this 
Code made of any materials other than imitation leather, shall be paid 
at no less than the rate of 45</- per hour" ; and 

The application of said Section 2 of Article IV having been stayed 
by Section 1 of the Administrative Order of I.iarch 14, 1934 approving 
said Code until such time as the Code Authority shall present to the 
Administrator a definition of the term "semi-skilled employee" which 
receives the approval of the Administrator; and 

The Code Authority having been unable to present a definition of 
said term acceptable to the Administrator and all other attempts to 
secure a satisfactory definition having failed; and 

It being also provided in Section 5 of Article IV of said Code 
that "The Administrator may uoon recommendation by the Code Authority 
and after full study and investigation by the Code Authority and after 
such notice and hearing as he shall prescribe, establish as a part of 
this Code such basic rates for the more skilled classes of employees 
as may be necessary to further effectuate the purposes of the Act; and 

It appearing to me necessary, notwithstanding that the Code 
Authority has made no recommendations as to the establishment of basic 
rates for the more skilled classes of employees, that a study be made 
of the Industry to determine the desirability and practicability of the 
establishment of such basic rates; and 

It being also provided in Section 1 of Article III of said Code 
that "no employee shall be permitted to work in excess of forty (40) 
hours in any one week nor in excess of eight (8) hours in any twenty- 
four (24) hour period; and 

Recommendations having been made to me that said hour provisions 
has not tended to effectuate the purposes of the Act by the relief of 
unemployment in the Industry; and 



9 811 



-259- 

It being also provided in Section 10 of Article 7 of said Code 
that "no member of the Industry shall give out work to be performed in 
any home or dwelling place except that this prohibition shall not apply 
to hand beading, hand crocheting or hand embroiderying, and except that 
hand sewing at home shall be permitted until July 1, 1934, but not to 
be T emitted thereafter. The Code Authority shall, in conjunction with 
such State Governments and such departments of the Federal Government 
end such other agencies as the Administrator may designate, study and 
investigate the problem of homework in this Industry and shall make to 
the Administrator recommendations for the effective and appropriate con- 
trol of such homework as is herein permitted. Should the Administrator 
find it to the best interest of the Industry or to the best interest of 
labor or otherwise necessary to further effectuate the purposes of the 
Act, he may further restrict or wholly prohibit the practice of homework 
in this Industry"; and 

It appearing desirable that the Administrator undertake a study 
of the problem of homework in this Industry, independent of the study 
being made "oj the Code Authority. 

HOW, THEEEEORE, pursuant to authority vested in me by the Adminis- 
trator for Industrial Recovery and otherwise, I do create an Adminis- 
trator's Commission for the Ladies' Handbag Industry with such powers 
and duties as are hereinafter set forth and as may be hereinafter assigned 
to it; and I- do hereby appoint as the members of said Commission the 
following named persons: 

Dr. Earl Dean Howard, Chairman 
Art hur S . Ro b e r t s 
Carl Rauschenbush 

and 

I do hereby ORDER that said Commission shall undertake immediately 
a study of the labor conditions in the Ladies' Handbag Industry with 
particular reference to the unemployment existing therein, competition 
between the various markets of the Industry, and homework; and I do 
further 

ORDER that said Commission shall report to the Administrator on or 
before August 15, 1954 with its recommendations as to a definition of 
the term "semi-skilled employee", as to the feasibility of establishing 
as a part of said Code basic rates of pay for the more skilled classes 
of employees in said Industry, as to the practicability of a further 
reduction in the maximum hour provisions of the Code for the purpose 
of relieving unemployment in said Industry and as to the advisability 
and practicability of further restricting or of entirely eliminating 
homework in said Industry. And I do further 

ORDER that the members of said Commission shall be compensated 
for their services by the Code Authority of the Ladies' Handbag 
Industry. 



9811 



-26 C- 



This Order may "be modified or revoked at any time hereafter. 



Sol A. Hosen'olatt 
Division Administrator 



Ami" oval "ecommended 



David 3arr 

Assistant Deputy Administrator 
Apparel Section 



Dean G. Edwards 
Deputy Administrator 
Apparel Section 



9811 



-261- 



EXHIBIT L 



Memoranda covering certain Amendments 



9811 



-262- 

EXKIBIT L 
MEMORANDUM 



August 21, 1934 



TO: J. G. Latimer, Division Legal Adviser, Division Three 

FROM: George L. Berry, Division Administrator, Division Three 

SUBJECT: In the matter of Approval of certain Amendments, pending 
to the Ladies' Handbag Code. 



The code for this industry was recently transferred from the 
Fifth Division to my Division, in which it is now assigned to Deputy 
Berry in the Leather Section. At the time this transfer was made there 
were pending for the Administrator's approval certain amendments and 
modifications of stays under this code. Hearings having been held on 
the questions, the files were prepared and the Assistant Deputy formerly 
in charge of the code, David Barr, had prepared his recommendation 
recommending the stay order contained in the original order approving 
the code be vacated, and further recommending that the pending amendment 
be approved. 

Since this code has been in Deputy Kerry's hands he has recom- 
mended that these pending matters be not approved and that they be dis- 
approved instead. However, subsequent to his recommendation to me in 
this matter, herewith attached dated August 20, the Labor Advisory Board 
has been pressing me recommending these matters i or the Administrator's 
approval. 

You will note from Deputv Berry's memorandum that there is a 
very serious problem involved of whether or not the approval would ajnount 
to the imposition of a provision of a code under Section 3 (d) of the 
Act or whether they can be properly approved under Section 3 (a) of the 
Act. IJill you kindly advise me of your opinion in the matter? 

There is attached hereto the record in the case and tentative 
orders, as well as the report of tne .Review Officer. Mr, Windsor, the 
code legal adviser in this case prior to the time of transfer, has 
rendered an opinion which you will find in the files approving the pro- 
posed actions, but I am quite sure that if you will confer with him he 
will give you information which will be valuable to you in connection 
with this case. 

Since considerable controversy has developed as to the legality 
of such approval and whether or not it would amount to an imposition of 
a provision of a code, I am requesting your opinion in the matter. 

In case you may desire further information, Assistant Deputy Ore 
who handles this code will, I am sure, be glad to consult with you at 
your request. 

George L. Berry 
L E ORE/ah Division Administrator 

9811 



-263- 



7T RA Tuesday 

Legal Division August 28, 1934 

MEMORANDUM 

To: Cnpt. J. F. Battley, Acting Division Administrator 

Division III 

From: J. '3-. Latimer, Division Counsel 

Subject: Proposed Amendment of Article IV Section 2 of the 
LADIES HAND BA& INDUSTRY CODE 



I was requested by George L. Berry, Division Administrator of Divi- 
sion III, for the Legal Division's opinion regarding the approval of 
Executive Order amending Article IV Section 2 of the Ladies Hand Bag In- 
dustry Code, and in compliance with that request herewith transmit to 
you my opinion. 

Said Article IV Section 2 reads as follows: 

"No semi-skilled employees engaged in cutting, framing paring, 
pocket hook making and/or operating (except lining operations, 
cementing and/or pasting) employed in the manufacture of any 
of the products covered by the provisions of this Code, made 
of any materials other than imitation leather, shall be paid 
at less than the rate of forty-five (45^) cents per hour." 

The Order of the Administrator for Industrial Recovery approving 
said Code provides as a condition of approval in part as follows: 

"Section 2- of Article IV be stayed until such time as the 
Code Authority shall present to the Administrator a defini- 
tion of the term 'semi-skilled employee' which receives the 
approval of the Administrator." 

The proposed modification provides for the deletion of the word 
"semi-skilled" and the words "made of any materials other than imitation 
leather" from said Section 2. 

The following provisions in the Code have reference to modification 
of same, to-wit: 

"Article IX Sectionl. This Code and all the provisions there- 
of are expressly made subject to the right of the President, 
in accordance with the provisions of sub-section (b) of 
Section 10 of the National Industrial Recovery Act, from 
time to time to cancel or modify any order, approval, license, 
rule or regulation issued under Title I of the said Act and 



9811 



-264- 



specif ically, "but without limitation, to the right of the 
President to cancel or modify his approval of this Code or 
any conditions imposed by him upon his approval thereof." 

"Article IV Section 6. The Administrator may, upon re- 
commendation "by the Code Authority and after full study 
end investigation "by the Code Authority, and after such 
notice and hearing as he shall prescribe, establish, as 
a part of this Code, such basic rates for the more skilled 
classes of employees as may be necessary to further ef- 
fectuate the purposes of the Act." 

The examination of the record of the public hearing held in refer- 
ence to the proposed amendment to the Code discloses the following: 

1. The Code Authority for the Industry was unable to agree 
upon a definition of "semi-skilled employee". 

2. A substantial majority of the Industry members object 
to the approval of the proposed amendment to Section 2. 

3. The amendment, while purporting to provide for a min- 
imum wage, will in reality under existing conditions 
in the Industry, provide for a maximum wage for a sub- 
stantial number of the employees, and, in effect, impose 
a wage scale. 

Section 7 (a) (3) of the Act provides as follows: 

"... that employers shall comply with the maximum hours of 
labor, minimum rates of pay, and other conditions of em- 
ployment, approved or prescribed by the President." 

Section 7 (c) authorizes the President to prescribe a limited Code 
of Pair Competition "fixing such maximum hours of labor, minimum rates 
of pay,****" . 

The above sections of the Act are cited as excluding, at least by 
implication, the writing of wage scales in codes of fair competition 
and, in my opinion, it is beyond the purview of the Act to prescribe the 
maximum, as distinguished from the minimum, wages. 

The testimony taken at the public hearing shows that the great major- 
ity of employees in this Industry at the present time are located outside 
of the metropolitan area and that the average wage for such outside em- 
ployees is $18.00 per week. The testimony also indicates that under pre- 
sent conditions a weekly wage of $18.00 would tend to fix a maximum wage 
for the majority of employees, nctually engaged in the Industry. 

It is my opinion that under the circumstances it is doubtful whether 
the President could legally impose the above amendment over the objection 
of a majority of the members of the Industry. 



9818 



-265- 

On the ground of policy, I think the amendment is definitely objec- 
tionable because the factual showing is not sufficiently strong to justify 
the unusual procedure of imposing a modification of this character over 
the objeftions of a substantial majority of the members of the Industry. 

/s/ J. G. Latimer 
J»- G. Latimer 
jgl*mb Division Counsel 



NEA Thursday 

Legal Division September 6, 1934 

MEMORANDUM 



To: Colonel H, S.. Berry, Deputy Administrator 

From: J. G« Latimer, Division Counsel 

Subject: Approval of certain Amendments pertaining to the 
Ladies Handbag Industry Code 



I have transmitted to Captain Battley, as Acting Division 
Administrator of Division III, my opinion in reference to the above 
subject matter, and have returned, to Major Berry certain documents which 
he transmitted to me, as follows: 

Record of Hearing 

Folder containing Order terminating stay of Article IV 

Section 2 of the Code together with supporting documents 
Copy of Executive Order approving amendments 

I am returning to you herewith the following documents: 

Memorandum of Alvin Brown dated August 15, 1934 

Memorandum from Review Division dated August 13, 1934 signed 

by S. M, Jeffrey 
Copy of legal opinion of Curtin uinsor dated July 31, 1934 

which documents I think you left with me. 



/s/ JGL 

J, G. Latimer 
Division Counsel 
jgl*mb 



9811 



-266- 



August 15, 1934 



TO: Division Administrator, Division 3 

FHOLi Review Officer 

SUBJECT: Stay of Article IV, section 2, of the code 
for the LADIES' lIAlvDBAG IIvlDUSTBY 



This order will not "be consistent with 
the Administrator' s former ".ction unless the ranend- ■ 
ment concurrently presented is approved. The question 
of approved seems doubtful. Accordingly, it is sug- ■ 
gested thr.t this order n oe withheld until such question 
has been determined.. 



Alvin Brown 
hi AB 



511 



-267- 



August 13, 1934 



REVIE./ DIVISION 



Order, Terminating Stay of Article 
IV, Section 2, of the Code 

for the 
LADIES ilAHDBAG IhDUSTRY 



Labor Advisory Board, Leg~l Division approve. Division 
of Research and Plannin reprove with suggestion. Con- 
sumers' Advisory Board reports, "but does not comment. 
Industrial Advisory Bor.rd disapproves. 



Administrator's Order : Provision having been mr.de in 

Administrator' s Order approving code r.s a condition of 
approval that Section 2, Article IV, (providing wages 
for semi-skilled employees in certain departments of not 
less than 45rf per hour) be stayed until code authority 
defines satisfactorily to Administrator term "semi-skilled 
employee". Code Authority unable to agree on definition, 
necessary in order to effectuate policies of Act that stay 
be terminated. 

Industrial : disapproves; no reason . 

Research and Planning : sixg^ests no objection to 
termination of stay, provided a wage differential on 
the type of material used in making of hand bags is 
maintained en some equitable differential to trice 
care of the small 'town manufacturer producing volume 
merchandise at low prices. 

Deputy : answers: this matter not properly within 
the scope of this Order. 



E. i.i. Jeffrey 
DJD:mah 

Received for Review August 13, 1934 10:00 Ai.i 
Forwarded with Review August 14, 1934 .6:15 PLI 



9311 



-268- 
C P Y 

Legal Division 



July SI, 1934 



i.iEi.iCRAI'DTJIi 

TO: Assistant Deputy Administrator Barr, Room 5016 

FROM: Curtin Jinsor, Assistant Counsel 

SUBJECT: Proposed Modification of Article IV, Section 2 
of the Code — Ladies handbag 



You have me recommendations mr.de up sometime ago in which I 
stated that it was doubtful legally whether tie President could impose 
an amendment tc an approved code, and me objections to the proposed 
amendment on the grounds of policy. 

You now ash for my opinion as to whether the problem of semi- 
skilled employee can be taken care of by having the Administrator lift 
the stay of Section 2, Article IV, provided for in the order approving 
the Code and by having the President sign an order modifying the Ad- 
ministrator' s Order approving said Code that the word "semi-skilled" 
and the words "made of any materials other than imitation leather" shall 
be deleted from this Section. 

Article IX, Section 1 of the Code provides in part as follows: 

"This Code .iiu all tne : provisions thereof ".re expressly 
made subject to the right of' the President, in accord- 
ance with the provisions of Sub-section (b) of Section 10 
of the National Industrial Recovery Act, from time to time 

to cancel or modify an order, approval, issued under 

Title I of the said Act and specifically, but without limi- 
tation, to the right of the President to cancel or modify 
his approval of this Code or any conditions imposed by him 
upon his approval thereof". 

In my opinion, the elimination of the words above referred to from 
Article IV, Section 2 in tLe Order falls within Article IX, Section 1 of 
the Code and Section 10(b) of the Act. Legally, therefore, your 
proposed solution is probably in order. 

My objections on behalf of the Legal Division to the proposed 
amendment on the grounds of policy apply with equal force, however, to 
the new proposal. 1 Our legal rights are not so definitely established 
that we should attempt to test them against the wishes of a united 
Industry unless our reasons for doing so are so strong as to warrant 
such a test. I am unable to see that they are that strong in the pre- 
sent instance. 



Curtin "Jin s or 



9311 



-269- 



Thursday 
NRA September 6, 1934 

Legal Division 



LiEiiCHA^Dyii 

To: I.iajor George L. Berry. Division Administrator 
Erom: J. G. Lr.timer, Division Counsel 

Subject: Approval of certain Anendments pertaining to the 

LADIES KALDBAG INDUSTRY CODE 



A few days ago, in response to your Memorandum 
of August 21 in reference to the above subject matter, I transmitted 
my opinion regarding the legal aspects of the proposed approval of 
amendments to Captain Battley on the assumption that, as Acting 
Administrator for Division III, such opinion should be delivered to 
him. 

I failed at t.iat time to return certain docu- 
ments which were forwarded to me, which documents are as follows: 

Record of Hearing 

Polder containing Order terminating stay of Article IV Section 2 

of the Code together with supporting documents 
Copy of Executive Order approving amendnents 

These documents are returned to you herewith. 



/s/ JGL 

J. G. Latimer 
Division Counsel 



jgl*mb 



9811 



-avu- 



EXHIBIT M 



Digest of Hearing,. May 7, 1934 



9811 



-271- 

EXHIBIT M. 

DIGEST OF HEARING HELD MAY 7, 1934 

Before Assistant Deputy Worthy and his Advisors 

Miss Rose Schneiderraan Labor Advisory 

Mrs. Cunningham Research and Planning 

Mr. Curtis Winsor Legal 

The protestants were: 

G. R. Godfrey Co., Gardner, Massachusetts 
Hudson Leather Goods Co. Inc., Nyack, New York 
Paragon Novelty Bag Co. Inc., Newburg, New York 
Uneeda Novelty Bag Co. Inc., Newburg, New York 
Newburg Handbag Co. Inc., Newburg, New York 
Licht & Kaplan Inc., Newburg, New York 
Strand Leather Goods Co. Inc., New York 
Virginia Art Goods Co. Inc., Lynchburg, Virginia 



Basis of protest: 



Did not participate directly or indirectly in 
establishing or consenting to a code and were 
particularly harmed by provisions: 
Sections 1 and 2 Article III 
Sections 1, 3 and 6, Article IV 
Wage Differential not provided. 



Provisions complained of: 

Hours, Wages, Learners and Classification. 



The arguments presented were: 

Learners - inability to obtain trained help. 

Wage Differential of thirty cents - inability 
to pay and inability to compete with others 
in a more advantageous position. 

Hours - need of longer hours for office staff. 



All protests disallowed under Orders 332-4-5-6-7 signed by Earl Dean 
Howard, Deputy, with exception of Virginia Art Goods Company, Inc. 
held in abeyance. 



9811 



-272- 



HISTORY 

of the 

CODE OF FAIR COMPETITION 

for the 
LADIES IIMiDMG- INDUSTRY 

Volume II 



' 



9811 



-273- 



EXHIBIT "N» 
Administration Member's Reports 



9811 



-274- 

EXHIBIT N 

March 30, 1934 

Dr. Earl Dean Howard 

National Recovery Administration 

Washington, D.,. C. 

Re: Homework 
Dear Dr. Howard: 

The more I look into this question the stronger becomes my convic- 
tion that to arbitrarily do away with this practice would work grave 
injustice to employer and employee alike. 

As you are probably aware, Codes already approved forbid this 
practice on and after certain set dates. Perhaps it was a majority of 
manufacturers in the several industries affected who selfishly wanted 
this rule made absolute and prevailed in their argument. Undoubtedly 
they marshalled a great mass of supporting evidence which warranted the 
Administration forbidding the practice. 

My personal feeling is one of opposition to the practice. I know 
of the evils that have and do exist. I know of the unsanitary conditions 
that so generally prevail, and I recognize the frightful exploitation of 
the human factor. Notwithstanding all of these conditions, I must remember 
that the people affected, employer and employee alike, have a stake in 
this form of operation, and to destroy that is a serious matter. Thile 
I believe it is true that a certain percentage of such workers can be 
absorbed into factory operation, I am certain that a quite large percentage 
cannot, and it is of these I am particularly concerned. Their earnings, 
pitiful and small as they have been are an important part of the home 
economy, and one cannot ignore it, for to do so would be a grave injustice, 
and would tend to add to the great want that already exists. 

Difficult as the matter of regulation is, and of necessity will be, 
I am very certain today that drastic regulation can be made effective, not, 
of course, 100$, or perhaps approach that, but sufficiently to bring about 
a vast improvement. 

It has been suggested to me that a form of licensing through a state 
agency and a paid policing through the several Code Authorities affected, 
could be brought about, and would be of tremendous help. 

The suggestion made provides for a fairly stiff licensing fee - one 
that would to a degree at least, keep the irresponsible employer out of 
the picture, and on top of that, they be required to pay a sum to their 
Code Authority sufficient to provide for the policing. The burden of 
proof as to the cleanliness of the home where work goes, and as to the rates 
of pay, would be placed squarely on the shoulders of the employing . 
manufacturer, and sworn statements from him as to compliance be required 
with an agreement that extremely heavy penalties could be summarily in- 
flicted for noncompliance, all of which he would agree to when he made 
application for his license. 

9811 



-275- 

After inquiring into this subject on "both sides of the picture, 
it is my considered opinion that homework should not "be abolished and 
that a form of regulation such as indicated above, should be required. 

Very truly yours, 



0. T7. Pearson 



0WP:HA 



April?, 1934 



Dr. Earl Dean Howard 

0. W. Pearson 

Bag Code Authority 



Organized this Authority Tuesday night, April 3, 1934. Meeting 
developed that a buyer's strike is threatened, probably in New York, 
over the new terms laid down in the Code. Suggested that it would be 
a threat only, but in the meantime would be good to get in touch with 
the Retail Code Authority and point out that the strike threat is 
based upon the idea of infringement of the Bag Code. 

Out-of-town factories asking for apprentices. Matter to be 
investigated and report made immediately. 



0. W. Pearson 



OWP : MP 



9811 



276- 



COLLECT AT NBA HEADQUARTERS AT WASHINGTON, D. C. 



POSTAL TELEGRAPH 



MAY 17, 1934 



JAMES C WORTHY 

ROOM 4318-DEPARTMENT Of COMMERCE BUILDING 

WASHINGTON, D. C. 



I HAVE CAREFULLY EXAMINED ITEMIZED BUDGET OF THE 
LADIES HANDBAG CODE AUTHORITY IT HAS MY APPROVAL 
STOP THE METHOD OF RAISING MONEY TO MEET EXPENSES 
OF ADMINISTERING CODE IS I BELIEVE SOUND AND BASED 
ON GOOD PRACTICE STOP I HAVE LOOKED INTO THE ITEMS 
RELATING TO REMUNERATION AND FEEL THEY ARE PROPER 



0. W. PEARSON 
ADMINISTRATION MEMBER 



ROOM 404-405 



9811 



-277- 

NATIONAL RECOVERY AD1.II1TI STRATI Oil 

WASHINGTON, D. C. 

45 Broadway 
New York City 



May 11, 1934 

Dr. Earl Dean Howard 
Deputy Administrator, Div. V. 1IRA 
Department of Commerce Building 
Washington, D. C. 

My dear Doctor Howard: 

IN RE: LADIES HANDBAG CODE AUTHORITY MEETING 
T HURSDAY- MA Y 10. 

The first order of business scheduled for last night's meeting was 
settlement of the natter of definition of semi-skilled workers. I am 
sorry to say that it was no cess- ry to postpone this matter again. 
This was the condition that I found. 

The New York group are now negotiating with labor for a new agreement. 
Based upon past experience, they ca?ie to me last night, and pointed out 
that if this definition were immediately settled, and under this new 
definition the out-of-town seni-skilled workers would be raised, the 
Labor Union in New York would immediately insist upon a -oro-oortiona.te 
increase being made for this group in the New York area., which would 
immediately :>lace New York in the bra competitive position with respect 
to the out-of-town manufacturers. 

I also discovered that the committee had been unable to agree, there 
being a. sharo division of opinion, divided on the ba.sis of 4 to 3 on 
each item taken up for settlement. In addition to that, Labor itself 
turns in a. third reiort. I have agreed to make visits to some factories 
during this coning week for the purpose of seeing for myself exactly 
what is involved in these various operations and can present a more in- 
telligent opinion as to what is a prober definition. 

I trust this will meet with your approval. Much as I regret the delay, 
I am convinced it was sound to again postpone it for a short time. 

I find the financial situation is not so hot. A request was sent out 
to the Industry to pay $25.00 each on account, to be credited against 
their Label orders. So far Industry had not responded. The Code Auth- 
ority can discount with the bank all orders for labels they receive but 
they cannot secure these orders until the budget set-up and label plan 
is approved. This I believe had been in Uashington for a week or two, and 
I wonder if it is possible to get some innediate action. 



9811 



-273- 



A number of -oetitions were presented to the Code Authority. Upon sone 
of these, action whs taken and I understood that respecting them Mr. 
Mittenthal will notify your office direct today. Others were laid 
over for the -our-iose of seeking further information. 

¥e will have set wo during this week the Trade Practice Corrolaints 
and Labor Cornnlaints Connittees rnd these will go forward for ^rour 
aporoval just as soon as nanes are selected and agreed uoon. 

There is seemingly a better state of mind with respect to the two 
groups coming into being. This was definitely ■ evident at the meeting' 
last night and I am sure this is welcome ne^s to you. 

Meeting adjourned about 12:40 A.}.'. 

Yours very truly, 



0. TJ. PEARSOil 
ADi.mil STRATI 017 MEMBERS 
OttP:DAR 



9811 



-279- 



COLLECT AT IffiA HEADQUARTERS AT WASHINGTON, D. C. 



POSTAL TELEGRAPH 



Itear 17, 1934 



jAi,Es,-c,..TTon?:Hr ;.;:;, . ;:; , ; ,, 

ROOii 4318 

DEPART1ENT 0? COIHERCE BUILDING 

WASHINGTON, D. C. 



UP Oil EXALHITATION LABEL COST OP TIE LADIES HANDBAG 
CODE AUTHORITY IS PROPER A3 HAS LT APPROVAL STOP 
CODE AUTHORITY SHOULD BE PERi.HTTED TO PURCHASE Alb 
ISSUE TSRI1 STOP THE ISSUING OP LABELS WILL BE BASED 
UPON THE VARIOUS PRICE-LINES OP TIE INDUSTRY AIID ARE 
COiEUTED UPON AH EQUAL BASIS OP APPROXIMATELY OIE 
THIRD OP ONE PERCENT 



0. W. PEARSON 
ADMINISTRATION 1EHBER 



Room 404-405 



9311 



-280- 
HAXIOilAL RECOVERY AD1.II17I STRATI OH 



May 25, 1934 



Hr. James C. Worthy 
Assistant De.mty Administrator 
National Recovery Adninistr t ion 
Washington, D.' C. 

HE : Ladies' Handbag Cod e Authority 
Dear Mr. Worthy: 

Shortly after this Code Authority started its session last night, 
Uotice of Hearing with respect to definition of seni— skilled workers 
and the plea for a change of the Code Authority personnel on the ground 
that it is not truly representative, was read and the fire works were 
on. I thought my millinery friends could fight but they don't know how 
to go about it as do the members of the Ladies' Handbag Code Authority. 
So much bitterness developed that I finally adjourned the meeting at 
ten-thirty and said if the industry members of the Authority cared to 
stay, I would be gird to sit up all night if necessary, and stay all 
day on Friday^ for the purpose of trying to arrive at an amicable settle- 
ment of the differences that e:cist between the various factions and 
groups. 

This they agreed to .do and, I asked that Labor and the code directors 
leave, I thereupon started the meeting which lasted until nearly four 
o. 1 clock this morning. When I made this offer, I, of course, realized a 
number of others had attempted to do the same thing, including your own 
good selves, but feeling that perhaps the situation might be a little 
different today as a result of the work, little as it has been on the 
surface, done by the Code Authority, I blithely set out on, what shall 
I say - my errand of mercy* Oh boy, I am a wreck today but I do see a 
little glimmering of light and the possibility of finding a common ground 
upon which they can all agree. 

The basis of my thought is that all present associations shall go out 
of business and that there be formed one new association, th • name of 
which is immaterial at this point, and the membership of if hich shall be 
all present members of the old groups; and that possibly the membership 
of the Code Authority should consist of a number of men representing 
out-of-town, equalling those representing Hew York or some such iroper 
basis. 

It then developed, and this is '-'here the greatest bone of conten- 
tion lies, that the proposed definition of semi-skilled workers is the 
kernel of the whole situation. It seems to be evident that there is too 
wide a labor cost differential existing between lie-" York and out of town. 
Of course, out of town feels this is not so but as is usual., neither side 
has any facts upon which one can reach a reasonable conclusion. 

9811 



-281- 



Finally, at four this morning, I stiggested that I procure from 
out of town manufacturers and an equal number of He" York manufactur- 
ers, say four to six in each case, or at least enough representing 
each of the major price lines, a definite cost of operation figure 
which, of course, I can only get from a quick survey- b* r an accoun- 
tant during the next feu days. It was suggested that if I Tould do 
this, I might ask the Administration to postpone the 'hearing, set for : 
June 16 I think. They were pretty nearly of the opinion that they 
could get almost a one hundred percent agreement On the decision that 
I reached, 

I would like you to think this matter over and since I will he in 
Washington on Tuesday afternoon, perhaps you and I can sit down and dis- 
ucss it at length and see what you think of it. 

In the meanwhile, I have done this' much. Mittenthal is going to 
give me the names of the various manufacturers to whom I might go, and 
I will send a preliminary letter to them acquainting them of what I 
have in mind and its purpose and chiefly bespeaking their earnest co- 
operation. We can be turning over whatever books are necessary to the 
Cost Engineers whom I will see. 

In the meantime, too, I have asked Mittenthal to get in touch with 
as many members of the Code Authority as he can to see whether the Code 
Authority are agreeable to paying the necessary expense of this job, which 
I don't think will cost over two or three hundred dollars, at the most. 
If the desired results can be accomplished, certainly the effort is worth 
it. In fact it is worth a great deal more. 

Kindest regards. 

Sincerely yours, 

(Signed) 0. W. PEARSON 
0. W. PEARSOU 
ADMIITISTRATIOH MEMBER 
LADIES' HAHDBAG CODE AUTHORITY 



9811 



-282- 

MEMORAiJDULI 



June 9, 1934 



To: David Barr, Ass't, Deputy Administrator 

From: 0. W. Pearson, Administration Member 

Subject: Budget - Ladies Hand Bag Code Authority 

I think you saw enough of this Industry this week to realize that 
at the moment of writing it is a pretty sick Industry and has many dif- 
ficult problems facing it -which require very definitely the finest type 
of brains that are to be procured, if one is to look for the discovery 
of the sick spots and v/eaknesses at present existing* 

I think perhaps the title Planning and Progress Division of the 
Code Authority is not althogether a descriptive title, nor do I think 
the "Contributions to Associations for Code Authority work" are as well 
put as they might be. Briefly, the plan this Code Authority has in mind 
is the securing of a complete and definite picture of this Industry so 
that from the facts so disclosed one may be able to -orescribe the cura- 
tive dose that is necessary. 

Obviously, all of such work requires, as I mentioned above, properly 
qualified brains. Hence, it was that the Code Authority after long dis- 
cussion and examination, set up the Executive personnel of the Code Auth- 
ority as they did. It so hap oens that this Executive personnel "set up" 
is a peculiarly happy one and, if I may say so, almost, unique, at least 
in the Apparel Industries, since the three Executive heads are men of long 
experience in the Industry. 

The Executive Director in charge of Planning and Research is an 
ex-member of the Industry with better than thirty-five (35), years of ex- 
perience and knows the distributive problems of this Industry, perhaps, 
better than almost any other man in the Industry, in fact, he is acknow- 
ledged to be, what one nay term an expert in such problems. 

The Compliance Director is a manufacturer of thirty-nine years of 
experience, and unquestionably knows the mechanics of manufacturing from 
A to izzard. His job is a peculiarly difficult one requiring a most in- 
timate knowledge of industry and its practices. He must be of the high- 
est intelligence and integrity. 

The Executive Secretary is peculiarly well qualified for his posi- 
tion* With some fifteen years of experience in this Industry he has a 
broad knowledge of the strictly labor side of the Industry. It so hap- 
pens that labor problems involved are very acute and if one is to pre- 
serve the integrity of the Industry itself, it is, vitally important that 
the Code Authority should have the services of a man who is qualified in 
this direction. ly. .'addition his experience as Secretary of the Bag Trade 
Association has given him a ripe organizing experience. 

9811 



-283- 

From my talks with many members of Industry both on the Code Auth- 
ority and manufacturers who are not on the Code, including the most 
recalcitrant members of Industry, all of these executives are reported 
to me to be of the highest integrity and the industry fsels they are 
fortunate in obtaining the- -services of these men. In passing it may be 
interesting to know that as a result of the efforts of these men a great 
many thousands of dollars have already been collected and paid in re- 
stitution to workers, and it is further interesting to know that these 
men are so interested in their work they have worked for almost three 
months with but the payment to them of three weeks salaries. 

Personally I feel the Industry is to be congratulated upon having 
this type of executive personnel, and I co-old wish that the same condi- 
tion existed in the other industries with which I have been associated 
these past several months. You must also bear in mind that not alone 
have these men not been paid and yet have been Trilling to work, but 
that the Code Authority has had practically no funds with which to oper- 
ate for travel and other expenses. This of course, has been due to the 
fact that they did not want to start the sale of labels which would pro- 
duce the necessary revenue, until complete approval of the labels, their 
sale, and the budget was had from the Administration, This is, I think, 
something to the credit of" the Industry in contradistinction with cer- 
tain other industries who have proceeded without waiting for approval* 
This Authority has leaned backwards in their desire to see to it that 
the law is obaerved and that they themselves do not transgress the rules 
and regulations set forth by the Administration. 

I think the breakdown of the Budget as originally presented can be 
improved so that perhaps it will show a decrea.se in the total revenue 
and expense, not perhaos a tremendous reduction, but none tho less a 
reduction of several thousands of dollars. 



0. y. Pearson 
Administration Member 



9811 



-284- 



0. 17, PEARSON 

ADI IIUI SERAI I Oil i.ESi SDR 

45 BROADWAY, KEW YORK CITY 



IiRA HEADQUARTERS 



DAVID 3ARR. 
DIVISIOIT FIVE, IffiA 
BEPART1E1TT OP COifiDSRCE BUILDING 
WASHIIIGTOIT, D. C. 

I All TO HAVE MEETIIIG ITITH A BAG IIAITUTACTUIIERS GROUP. 

M01TDAY MORIIIIIG STOP BELIEVE 1LAY BE ABLE TO PIIID SO- 

LUTIOIT PRESENT PROBLEMS STOP T7ILL GET 117 TOUCH ITITH 

YOU SOOil AS UEETIHG CONCLUDES ■ 



0. 17. PEARS OIT 

AD11I ill S THAT I Oil i iEI/IBER 



ROOI.l 800 



9311 



-28 5- 



NATIONAL RECOVERY ADMIill STRATI Oil 



45 Broadway 
New York City 



Digby 4-2324 



July 2, 1034 



Mr. Dean G. Edwards 
Deputy Administrator, Div. V. I1EA 
Department of Commerce Building 
Washington, D. C. 

Dear Mr, Edwards: 

SUBJECT: LADIES'. HAiTDBAG- INDUSTPY 

This industry made another step forward in the program that we laid 
down for them some weeks ago and upon which I have sient so much time. 

After the Code .Authority meeting held last Thursday afternoon a 
Mass Meeting* of the two fighting organizations was held for the purpose 
of carrying out an agreement entered into with me by a committee repre- 
senting a group at a meeting held in Washington prior to the last public 
hearing. 

At this mass meeting it was formally agreed that the t"0 associ- 
ations should unite and carry on a constructive program looking- forward 
toward rehabilitation of this Industry. 

As you know the picture here is a. rather sad one. Its volume is 
down to about half of what it was two or three ye-rs rgo raid I am very 
certain that the profits have entirely disappeared. 

The Labor Unions pre making a stiff fight on the matter of Industry 
removing itself from New York City to other parts of the oountry. They 
are at present taking issue with one particular concern who a week or two 
ago removed its factory from this city to Massachusetts. So strongly 
do the Unions feel that they are making an issue of it with the NBA and 
there will be a hearing at #45 Broadway, this morning at 10 A.M., at which 
I am to be present, respecting this com >laint. 

The story back of this removal is an interesting one. Both Mr, Barr 
and myself have taken the postition that there is nothing that prohibits 
the removal of a 'factory from one -ola.ce to another, but as I understood it 
the Union insists that the manufacturer in question take along with him 
all of the employees working in New York. The manufacturer refuses to do 
this on the following grounds. As a result of shrinkage in his capital 
and assets he could no longer obtain ba.nk accommodations in the city of 
New York. Some months ago he learned of a vacant factory in Massachusetts 
located in a. small town that has been closed for over a. year, throwing two 

9811 



-236- 



to four hundred people out of work. This factory closed because of the 
dry rot that had set in the" firm that had formerly', conducted the busi- 
ness. Their business ^as comparable to handbags so that the former em- 
ployees are more or less familiar with processes of bag manufacture. 
This New York concern having learned of this found that the local banks 
there would give it whatever accomodations it needed, provided it re- 
opened that factory and took off tho relief rolls of that town the former 
employees of that factory. 

This Mew York manufacturer had not contractual relations with the 
New York Local Union, contract having expired on June 1st. The union 
and Industry have not 'oeen able to agree upon terms for the renewal of 
their contracts and I suspect that this delay in settling a new agree- 
ment is based upon the ho^ that out of the mblic .hearing scheduled 
for July 9th one side or the other will be in a more advantageous posi- 
tion for making terms than they are today. 

The whole situation in this Industry is bad. Now that the associa- 
tions have joined forces, and provided the breath 'of life Is put into 
it, possibly they can begin to work toward the solution of the many pro- 
blems facing them. 

Here to, as in Millinery, the price structure, their basis of figur- 
ing costs, (I suspect inefficient factory operation), the buying of orders 
rather than selling are the troublesome factors.. 

Here again I hope to be able to give them the benefit of raj" own ex- 
perience along those lines that should look forward to a better state of 
affairs. 

Yours very truly, 

/s/ 0. TT. PEARSON 



; 0. W. PHAESOi! 
IDi.IIlil SERAI I ON ; £; 3EH 



OtfPrDAR 



9811 



i87~ 



0. U. PEARS01I 

ADiiliTISTEATIOir HEIiBEE 

45 Broadway, KEU YORK CITY 



1IRA Headquarters 



July 26, 1934 

DAVID BARR, ASSISTANT DEPUTY ADKIITISTRATOR, DIVISION 

FIVE, ILIA 
DEPARTMENT OP COMMERCE BUILDING 
WASHIiTGTOli, D. C. 

I RECCiniEITD THAT EXEMPTION AS CQEFERRED 3Y PARAGRAPH THREE 

ADMINISTRATIVE ORDER #36 "BE TERMINATED FOR LADIES 1 ' HANDBAG 

INDUSTRY 



0. ¥. PEARSON 
ADMINISTRATION. IffiMBER 



(this tele^jran sent over Administration Members own private 
wire) 



9811 



45 Broadway, 11. Y. C, 



September 10, 1934 



Colonel Harry Berry 
Division 3 
Commerce Building 
Washington, D. C. 

IG: Lrdies Handbag Code Authority 

My dear Colonel 3erry: 

I enclose herewith sone statistics of work done with respect to 
compliance in this industry 7 . ■ - 

When one considers the disability, due to lack of finances, under 
which this Code -Authority suffered during the first two or three months 
of its life, one cannot help hut be astounded at the amount of ground 
covered by the Code Authority Directors. 

Up to July 1, they had no investigators; employing their first 
man on July 1, the second August 20; and the third, August 27. I think 
you will go a Ion,; way before you find another code authority that has 
worked as conscientious^, and that has rccora^lisheu as much as have 
these same two gentlemen. Please note, thfly have had in excess of ten 
thousand dollars paid in restitution. 

I understand you wero in town last week, and I am sorry I did not 
see you. 

With kind regards, I am, 

Sincerely "-ours, 



0. W. PHARSOU 

Administration iienber 



HB 
E1TC. 



9811 



-PR9- 



45 Broadway, II. Y. C. 



September 28, 19S4 



Colonel Harry Berry 
Divisional Administrator 
Commerce Building 
Washington, D. C. 

ES; Lad ies 1 Handbag Code Authority 

My dear Colonel Berry: 

This Code Authority met last night, and I invited Speical Deputy, 
Doctor Schaeffer, who, as you probably know, is in charge of adminis- 
tration work in Hen York, to be present. 

The meeting was a little less boisterous than usiial, and it was 
interesting to note that, not withstanding the general strike situ- 
ation, which is so seriously affecting everyone, good spirits prevailed. 

In private conversations with one or V' r o manufacturers before the 
meeting, I was informed that the strike is much more seriotis than per- 
haps I thought, and that it is doubtful, if it lasts another - T eek, if 
many of the manufacturers .can stand the gaff.. The Communist element is 
definitely in the saddle and -I am afraid that if manufacturers have to 
giye in to the Communist demands, you will have the same situation! develop 
here as is the case in the Pur iianuf acturing Industry. 

It is generally believed that the rank and file of workers are just 
as anxious to go back to work as are the manufacturers to have them. I 
was also informed that one small manufacturer had already signed the new 
agreement. 

I further learned, ar.d during the course of the meeting remarks 
about it were made openly, that there will be definite migration of in- 
dustry from Hew York, and- that it is the general feeling that in that, 
and only tha.t, lies salvation. I was told that a number of manufacturers 
have been scouting around during this past week looking for loca.tions. 
From the point of view of organized labor, this, of course, will be death, 
because of the obvious' impossibility of holding the industry within the 
ranks of labor organization. I7hether the industry can stand the cost of 
moving, is of course, an open question. However, I think Chambers of Com- 
merce and other similar bodies in the smaller centers trill do everything 
they can to help finance such a move. 

The early part of the meeting was given to the reading of various 
petitions asking for learners, apprentices, overtime, and so forth. Most 
of these, in fact I think all of them, were rejected on the grounds that 
the position taken by the wetitioners was unsound. These will, of course, 
go forward to you from the Code Authority Officers, 
9811 



-290- 

There was also brought to the attention of the Code Authority 
your request for immediate approval of an amendment to the code, chang- 
ing the wage scale and deleting two troublesome paragraphs relating 
to semi-skilled definitions. 

I had a telephone call late yesterday afternoon from Hiss 
Schneiderraann, who made an appointment with me for this morning. The 
ourpose of Ixer meeting with me was to discuss, or rather to impress 
upon the Code Authority through me, the insistence of the Labor Advisory 
Board that immediate action must be taken by the Code Authority on the 
matter of '-'ages, or that Board would immediately petition you to dis- 
continue the stay, and also that you write the definition of semi-skilled. 
I thought it -oolitic, therefore, to immediately phone the Code Director 
ajid arrange for a special meeting of the Code Authority, to be called 
not later than Monday noon, for them to formally accept or reject your 
proposals, and, in the case of rejections, to state their reasons for 
holding it over. 

While I realize that the industry has been much at fault in their 
dilly-dallying on this entire subject, I feel, myself, that at this 
ooint, hearing in mind the Communist threat, it would be unwise to press 
too hard for a final decision upon this. Although it is denied by the 
Code Director, I am of- the definite impression that Mr. Stein, the Labor 
Representative, present last night, agreed with this viewpoint* Miss 
Schneidermann will check on this at a meeting she expects to have with 
him la.ter this afternoon. 

The rost of the meeting was interesting, somewhat amusing and peace- 
able, and we finally, 7 adjourned at 10:15 p.m. 

In a. conversation I had yesterday with Captain Brickley, he informed 
me that it was his feeling I should come to Washington next week, and he 
would see you today about wiring me the necessary order. Perhaps you will 
be' good enough to remind him of this. 

Sincerely yours, 



0. W. PEARS02T 
B3 Administration iiember 



9811 



-291- 

NATI01TAL BECOVERY AD ill IT I STRATI Oil 
45 Broadway, 1T.Y.C. 



October 26, 1354 



Colonel Harry. S. Berry 
Deputy Administrator 
Division Three 
Commerce Building , 
Washington, D. C. 



My dear Colonel Berry: 



KB: Ladies' Handbag Code Authority 



The meeting of this Code Authority lest night was somewhat tumult- 
ous, but I felt, by the time the long session was over, that the members 
would be able to reach an agreement with trie Administration with respect 
to the matters in dispute ^or so long. 

I was particularly glad that i.lr. Ore was -'resent, because, although 
they did not for the moment accept the proposals made by him, he, speak- 
ing with the voice of authority, convinced them, I am certain, of the 
need of immediate settlement. 

The matters relating to wages aid hours and the definition of semi- 
skilled were referred to a committee on which I was asked to sit as a 
member. This committee will be called together by the Code Director next 
Monday. I suggested that, because of the importance of these natters, the 
Code Authority be re: uy to receive the coniittee's report next Thursday 
night, rather than wait for the regular meeting, which is not due until two 
weeks from last night. They finally agreed to leave the calling of the 
meeting in my hands. 

Mr. Ore seemed to have felt that, perhaps, he had too much to say 
on the proposals of the Administration, but I can assure you what was 
said was necessary to impress the Code Authority with the idea, that they 
can no longer dally over this subject. I believe his statements had a. 
salutary effect. I took occasion at the end of the meeting to point out 
their folly in consistently and persistently post )oning the evil day until 
the dim distant future, and that I was concerned over their lack of per- 
formance with respect to this important na.tter, and it '.-'as beginning to 
be evident they hadn't the courage to scuarely face the issue. 

We also took up the matter of alternates, lir. Ore jointing out 
that they are not permitted. The outcome -/.as their reminding me tha.t, 
in the herring last summer, the set-up of the ne~ Code Authority was 
placed squarely in ray hands. I am going to have a. meeting with the 
Board of Directors of the major association next Wednesday night which, 



9811 



in turn, will, I think, be followed by an industry meeting, and I hope 
from that a much better frame of mind will come into being and that I 
shall be able to send you my nominations for the three additional mem- 
bers and, perhaps, as amendment to "the" Code, enlarging the body, so that 
it rrill be more truly representative. 

Of course, we must all appreciate the strenuous time >. jbhe industry-ihas 
been having, and that many of the troubles, under which they have been 
laboring, have been the result of their own folly, rather than any sins 
of omission or commission on the part of the Administration. Knowing 
them as I do, I feel generally encouraged. 

Very truly yours, 



/s/ 0. 17. PZARS01T 



0. 17. P2AHS01T 
Adnir.i s tration i lember 



P. 3. Will you.be good enough to remind ilr. Ore that he is going, if 

it is possible, to send me, from the Research and Planning Divi- 
sion, the consolidated figures relating to this industry. Thanks. 

o„t;.p. 



9811 



-293- 

HATIONAL RECOVERY ADMI1TISTRAII01T 
45 Broadway, II. Y. C. 



Uovember 1, 1934 



Colonel Harry S. Berry 
Deputy Administrator 
Commerce Building 
Washington, D. C. 



KB: Ladies' Handbag Code Authority 

My dear Colonel Berry: 

The Committee appointed at the Code Authority meeting of last 
week, which is to make a recommendation to the Code Authority respec- 
ting the hour and wages provision, net aria sat for four hours yester- 
day and decided they wished to talk it over with the entire industry", 
which was to meet at eight o'clock last night* 

At the Code Authority meeting, it wrs determined - in fact, a 
very strong- wish was expressed - that I should be present. However, 
at the Committee meeting yesterday, there seemed to be a feeling that 
industry would talk more freely if neither the' Code Directors nor my- 
self were* present. Hence, I did not go. They did, however, invite 
the Counsel of the Association in the person of a Mr. Schlessinger. 

I am told this morning, confidentially, that Mr. Schlessinger 
made a wholely destructive speech, telling the industi^ that the IffiA 
was unconstitutional and that no code authority can levy an;/ assessments 
or collect* any other moneys from industry. The result of all this was 
a definite expression of feeling that they would not take any action with 
res-oect to hours and would not agree to anything in excess of the pre- 
sent minimum wage. i 

I am keenly disappointed about this, because last week, as I wrote 
you, I had hoped and believed cool heads would prevail ajid we could come 
to a satisfactory settlement. 

I presume the Code Authority will get together very shortly, raid 
take formal action in the matter, of which, of course, 70U will be duly 
advised. 

Very truly yours, 

/s/ 0. 17. PEARSOH 

0. 17. PDARSOII 

Admini s trr t i on Member 

KB 



9811 



-294- 



De censor 5, 1934 



Br. Schaeffer 
45 Broadway 
New York City 

RE: Ladies' Handbag Code Authority 

Meeting to be held Thursday night 
at 6:30, December 3, at the 
Hotel ilcAlpin 

Dear Dr. Schaeffer: 

In viei- of my confinement to "bed, I winder if you rill he good 
enough to have someone attend to this Code Authority ra'eeting in my 
place. 

There is one subject that must be brought up at this meeting. 
For some months past, the salesmen of this industry have been trying 
to persuade the. manufacturers to meet then for the -oumose of dis- 
cussing the mn.tter of their commissions and drawing accounts. Out- 
side of one brief meeting of a small committee some considerable time 
ago, nothing has been done. A deputation of these salesmen waited 
upon me on llondpy afternoon of this week and I agreed to bring the 
subject before the Code Authority at its meeting Thursday night. 

I take this ground. It is for the best interests of the indus- 
try to meet these gentlemen, and if they 'cannot accede to requests 
made, say so courteously and nlainly and give the reasons therefor. 
It does not make for good feeling and, therefore, cannot be of help 
to the industry to have any of its employees feel disgruntled. Some- 
times sore spots can be ironed out by having pl-^in, homely talks with 
the parties rffected, without, therefore, acceding to their demnnds. 

If I had been present at the meeting tomorrow, I was going to 
talk to the Code Authority along this line. iir. llittenthal, the Code 
Director, is fully familiar with tho situation. : 

TJhether the Code Authority or the industry agrees that these 
men' are entitled to consideration or not, at least they must agree 
they are entitled to the courtesy of a proper hearing and disposition. 

Attached hereto please find letter received from iir. L'ittenthal 
today, enclosing Plan for Control of Homework to be submitted at the 
meeting tomorrow for the approval of the Code Authority. 

Very truly yours, 



HB 

E1TC 



0. ¥. PSARSOIT 
Administration Member 
per 



9811 



-295- 



HATIOIJAL EZC0VERY ADMIITISTIlAlIOi; 
. 45 Broadway, K.Y.C. 

December 20, 19&4 

Mr. Leigh E. Ore 
Assistant Deputy Administrator 
Commerce Building 
Washington, D. C. 

RE: Ladies' Handbag Code Authority 

Dear Mr. Ore: 

I transmit herewith audited re-ort of this Code Authority for 
the month of October, 1934. As usual, this is pulj up in very complete 
form. 

There may he some question in the mind of either yourself or 
Planning and Research as to the si^e of the cash on deposit and on 
hand. I just want to remind you that they are ap iroaching the slack 
period and, in vie',: of that, this amount is not unduly large. 

Srdiibit C is .not quite clear to me. I am seeking farther light 
upon this 'fDom the Code Director -and when I obtain it, rail report to 
you. 

It is interesting to note, I- suoposo as a result of the strike 
this summer, the chrnges which h;-;v3 taken place in locatio?i of factor- 
ies in the 4,212 classified esnlcees working outside of Hew Tori:, as 
against 1,864 in Her: York. 

I feel that the conditions in this industry pre improving, -manu- 
facturers' morale has improved, and that there is a better mental ap- 
proach to their problems. 

I had an interesting session with the Code Directors and represen- 
tatives of the Traveling Srlesmen's association last Friday. This will 
be folio-red by one with officer; - of the Manufacturers Association today, 
and I hope, out o" it, "ill come a greater willingness on the part of 
manufacturers to consider the relationship between themselves aid sales- 
men in p somewhat difficult light than has been the case hitherto. Of 
this I will re-oort later. With hind re-rrds. 

Sincer ely your s , 



o. it. pdahso:: 

Ad: linis t rat ion Me; iber 
KB 



9311 



-296- 

NATIONAL RECOVERY ADLUNI STRATI ON 
45 Broadway, N«Y»C» 



January 4, 1936 



Mr. Leigh E. Ore 
Deputy Administrator 
Textile Division 
Commerce Building 
Washington, D. C. 



RE: La lies' Handbag Code Authority 

Meeting, Thursday, January 3, 1955 



Dear Mr# Ore: 



The most peaceful and constructive meeting I have ever had with 
this industrjr. The Code Authority covered a lot of ground and at all 
times approached the matters presented for their consideration in a 
thoughtful manner. The meeting adjourned at 11:00 p, n. 

The outstanding matter was the receiving of a deputation from 
the Imitation Leather Novelties Group, looking toward their coming 
under the jurisdiction of this Code Authority. This deputation pre- 
sented five or six points they felt should be considered by the Ladies' 
Handbag Code Authority. First, was representation; the second, discounts, 
two per cent as against three; third, cost formula; fourth, wage scale; 
fifth, method of voting on problems, relating to their groups. 

The Code Authority first considered the principle of bringing 
this group under their jurisdiction. This was unanimously ' agreed to as 
being' sound. 

Representation - Assuming an examination disclosed their volume 
is somewhere between four and five million dollars it was unanimously 
agreed the new group should have two representatives on the Code Auth- 
ority, provided they were additional members to the number provided 
under the present Code, 

Discount - This was unanimously agreed to without argument. In 
other words, this group should be permitted to continue on a two per 
cent basis. 

Cost Formula - Since there is no cos 4- formula provided under the 
Ladies' Handbag Code and they are now formulating such a plan, it was 
felt that it was unnecessary to do anything about this. 

Wa^e Scale - The unanimous opinion of the Code Authority was that 
the wage scale obtaining under the present Code should be the wage 
scale for this group. 



9811 



-297- 



Vpting. - It was unanimously agreed that the suggestion mr.de by the 
deputation, with respect to a two-third vote being required on matters 
strictly relating -to their "branch was not practical and that the majority 
vote, as provided under the new approved By-Laws, "be followed. 

Formal resolutions were spread on the minutes with respect to each 
item mentioned above. < 

It was agreeed that the Code Directors should consitute a committee 
to iron out any possible differences that might cone up so that the nat- 
ter can be presented for your approval at the public hearing next Wed- 
nesday. 

Apprentice Requests - These still continue to cone up and the 
Code Authority re-affirmed the position heretofore taken by it, which 
is one of opposition. 

Design Piracy - The plan as presented was unanimously approved.. 

Cost Formula - Since the committee's report on this subject had only 
been distributed to the members of the Code Authority two or three hours 
before the meeting, it was decided to lay it over until the next meeting, 
on the distinct understanding that each member would carefully study 
the report "so that the discussion at the later meeting would be to the 
point .and constructive. 

Salesm en- The Code Director, representing the committee of which 
I was a member, presented his report, but I took exception to a later 
development of which I had not been fully acquainted. At a meeting I 
had with the Salesmen's Committee, I aronised a deputation of salesmen 
would be received by manufacturers, at which time they should get a defi- 
nite yes or no answer. I made this promise feeling it was the politic 
and proper thing to do and for the best interests both of manufacturers and 
salesmen, believing that a face-tc-face meeting is good and, even if the 
answer had to be no, the other side will not feel they have been slighted. 
After my meeting with the salesmen, I held a session with the President 
of the Association, who was then leaving for California,. He agreed with 
my opinion in the matter and left the r.-p ^ointment of the committee of 
manufacturers in the hands of I.Ir. Mittenthal. Mr. Mittenthal consulted 
with these manufacturers and they evidently did not feel it was necessary 
to sit down with these salesmen and asked I.Ir. Mittenthal to convey to 
the salesmen their refusal of the demands made. It was to this I took 
exception. After all, salesmen are an important part of any manufac- 
turer's business and it is so foolish to build resentment and antagon- 
isms. I think the Code Authority in the main agreed with my strictures 
upon this action, or rather lack of action, and feel that within the next 
week or so there will be some sort of a get-together even if it does 
result in denial. 

Wew Members on the Code Authority - It was understood and agreed to 
at the public hearings that I should name three extra men to this body. 
This has never been done and I believe should be settled. I will dis- 
cuss this with you next week. 



9811 



•298- 



I understand the state of the industry has i no roved to a consid- 
erable degree. There axe still rumblings of labor troubles, but the 
season was one of the best had for several years past. The price 
floor lifted, slightly at leant, and the indications for the approach- 
ing season are all good. As is usual, the Code Directors are on their 
toes, always striving to do nore than their part helping the industry. 
I think more than any code directors I know of, they pay more attention 
to what is hapening in the retail stores, both in their advertising 
and in the conduct of the ladies' handbag departments. They are more 
alive to some of the follies committed by manufacturers and by retail 
merchants and are quick to express appreciation of what manufacturer 
or retailer may be doing that is helpful or constructive - all of 
which tends towrrd strengthening of good feeling, understanding and 
appreciation of the Code Authority's work, I am told the big manu- 
facturers, who bitterly fought the change in the discount structure, 
because of their fear of friction between themselves and important 
retail merchants, now find the new discount is acceptable and ceased 
grumbling - all of which spells considerable sums- of money in the 
coffers of the manufacturers. 

I shall be delighted to see you in Washington ne:ct wee. 1 :. I ex- 
pect to arrive Uonday morning. Uith kindest regards. 

Sincerely yours, 

/s/ 0. 17. PEARSON 

0. 17. PEARS0-! 

Administration itember 



9811 



-299- 

45 Broadway, N.Y.C. 

January 17, 1935 



Mr, Leigh H, Ore 

Assistant Deputy Administrator 

Apparel Section 

Commerce Building 

Washington, D. C. 

RE: Additional Member to the Ladies' 
Handha-q Code Authority 

Dear Mr. Ore: 

There is included in the order approving this Code the follow- 
ing: 

"That, in addition to other members of the Code Auth- 
ority, there may "be appointed by the Administrator or 
Elected "by such method as he may prescribe, in his 
discretion, not more than three additional members 
with voting privilege to be chosen from members of 
the industry who are not, in the opinion of the Admin- 
istrator, adequately represented on the Code Author- 
ity." 

At the time the Code Authority was originally set up, there were 
three major trade associations in existence, which between them repre- 
sented the larger portion of the industry located in the East, There 
is also one association located in Chicago and had a skeleton organi- 
zation on the Pacific Coast. Since that time, the condition has changed 
and two of the three major associations, headquartering in Hew York City, 
have been merged, and the third disbanded. While then it war, advisable to 
base the set-up of the Code Authority upon associations, I believe it is 
unwise to now consider from that viewpoint, and the industry is agreed 
to this. 

At the hearings held last summer, it was insisted \r/ the Admin- 
istration that the three additional members called for in the order of 
approval should be placed upon the Code Authority. After more or less 
acrimonious argument, the industry unanimously agreed that the appoint- 
ment of these three extra men should be left in the hands of the Admin- 
istration Member. It is to be noted that in all the discussions they 
laid emphasis upon their desire that the Administration Member, myself, 
make these appointments, I tried without effect to sidetrack this re- 
sponsibility, but since those days conditions have been markedly changed 
and I, therefore, present the following names for your approval: 



9811 



-300- 



Morris White 

Stylecraf t Leather Goods Co. , 

501 Seventh Ave. , IT. Y.- C. ■ 

J. Michel 

Michel, Maksik & Feldman, Inc. 

159 Madison Ave., IT. Y. C. 

A. Greenebaum 

Chic 3ag Co. , Inc. 

6 East 32nd St., IT. Y. C. 

Mr. Unite is generally called the Father of this Industry. He 
is the most colorful man in it. He has been somewhat of a problem to 
the industry because," while in his early days he was p .great builder, 
having lost his fortune, he seems to have changed his viewpoint and for 
a while it looked as though he -ere going to be the great destroyer. 
However, he has vision and imagination, lie can look at the problems 
from an industry viewpoint and since lie has great power for evil, I 
believe if we bring him into the fold we can make him a power for good. 
I, therefore, urge approval of his name. 

J. Michel has, since the inception of the Code Authority, been 
acting ps alternate. In his time he has been the great outstanding 
salesman of the industry. .': Today he hea.ds his own business and while 
he is of the excitable type,' still I have to credit him. with a grasp 
of affairs, and he definitely shows a do.sire to approach problems from 
the industry'-s viewpoint. I, therefore, recommend his name for appro- 
val. 

A. Greenbaum - I suppose there is no one in this industry who 
knows and understands as well as does Mr. Greenbaum the labor problems 
involved in the industry. He has upon a few occasions ap reared at Code 
Authority. meetings as an alternate and I an very certain he would be 
a, great addition to this group. I, therefore, ask for your approval 
of his appointment. 

The ap 'ointment of these three men would fill the- Code Authority 
and for these no amendment is necessary* This does not, however, take 
care of the two additional men required by the Ten-Cent to Fifteen- 
Cent Group. To provide for these two they desire that there be 'an 
amendment to the Code, which will be presented to you this coming 
wee]'. : 

You may ask why I do not recommend that these two last should 
be included in the three additional members already provided for under 
the order, and thus obvia.te the necessity of an amendment. My rea.son 
for not recommending such a procedure are as follows. 



9811 



-301- 



It will, in my judgment, "be for the best interests of all con- 
cerned to have a Code Authority set-up based uoon the broad price 
ranges, "because their problems, at least in so far as distribution 
is concerned, are somewhat different. I attach herewith the com- 
plete detailed set-up that we will have if your approval is given 
to these three recommended names and to the matter of an amendment 
to take care of the additional group. As you look at it, you will 
see that every price range is adequately taken care of and that 
geographical areas are properly represented. 



Very truly yours, 



0. W, PEAHSOIT 
Administration Member 



HB 
E1IC 



9811 



-302- 

NATIOL'AL RECOVERY ADMI'TISTRATIOir 
45 Bron.d-jpy IT. Y. C. 



January 31, 1935 



Mr. Leigh E. Ore 

Assistant Deputy Administrator. 

Apparel Section 

Corimerce Euilding 

Washington, E. C. 



RE: Ladies' Handbag Code Authority 



Dear Mr. Ore: 



Sometime ago I took occasion to moint out to the members of 
this Code Authority that if they could not attend meetings of the 
Code Authority, they ought to resign and permit someone else to take 
their place, that the "business of the Code Authority was important, 
and thr.t it was necesnrr3 r that all should he present, at least in 
so far as was generally possible. 

In looking over the records of attendance recently, I note that 
th.ese men, to whom I once before wrote on this matter, are still very 
neglectful of meecings. All cf tnese men are good men. They have some- 
ting to offer whenever they are ;or sent, and I think we should be con- 
cerned when they are absent as much as they are. The following is the 
record: 

Name Total Meetings Pre c ent Absent 
George Meyers 26 14 12 
R. IZoret 26 9 17 
¥m. Kadin 26 15 11 

I am wondering if a little reminder from you might not be advis- 
able. 

Very truly yours, 

/s/ 0. T7. FiuRSOIT 

0. U. PEAR 3 Oil 
Administration Member 
HB 



9811 



-303~ 

NATIONAL RECOVERY ADIIINI STRATI ON 
45 Broadway, IT. Y. C. 



IN EE: LADIES' HANDBAG CODE AUTHOFJTY 
MEETING FEBRUARY 19TK, 1935 



February 

twentieth 

1933 



Col. Walter Hangurn 

Deputy Adrninistrrtor 

Textiles Division, 

National Recovery Administration 

Washington, D. C. 

Dear Colonel Hangum:- 

For once this Code Authority started on time with its meeting in- 
stead of the usual sixty ninutes late, I wonder why it is that in one 
meeting out of every four, this grour> has to be a tumultous one? I 
thought last iiight, for a minute or two, that I wis going to lose my ' 
reason but towards the latter part of the evening - I suppose because 
they were tired out, rather than my influence - they did quiet down. 

The Labor member representative ap jointed to this Code Authoritj/ - 
seems to be on able citizen and desirous of understanding all problems 
that come before the Code Authority. He does not narrow dorm his in- 
terest to ihose matters strictly relating to labor but injects himself 
into every discussion relating to tra.de practices and other strictly 
industrial matters. Personally, I welcome this a.ttitude because I be- 
lieve many of these men have brains and know how to use them and oft 
times have a better viewpoint of industry's -problems than does the in- 
dustry itself. However, in this particular situation, it verges on 
being unfortunate, because of the resentment on the part of industry to- 
wards Labor and particularly towards this individual labor representa- 
tive because of their feeling tha.t the Union has gone Communist and 
that he therefore represents Communism. However, tine may cure this 
situation. 

The outstanding subject brought up was the hearing scheduled for Fe- 
bruary 28th and there was a very evident desire on the part of the Code 
Authority to have it -postponed. Nr. llittenthal pointed out that this 
might work harm towards the ne'-' group about to be abosrbed by this in- 
dustry. 

After listening to an extremely lengthy discussion of the whole sub- 
ject, I made the statement that nothing had been said that would lead me to 
support the adjournment plea made to you; that it was my belief the hear- 
ing should take "^lace, because sooner or later they had to face the settle- 



9811 



-304- 

raent of the long drawn out question of semi-skilled hours and wages 
end it might just as well he faced now as a month later. 

They then -or oc eo.de d with their plans for the hearing, going on the 
assumption that the hearing date would not he postponed and I think 
industry will he well represented at that time. Of one thing I am 
very certain. Labor will be t o11 represented and r strong fight will 
be made by that part of the industry. 

In reading the minutes of the preceding meeting, I was reminded 
that at that meeting, labor requested extra representation and wresen- 
ted a motion asking the Code Authority to recommend such to the Admin- 
istration. Finding no seconder, the matter was dropped. Labor bases 
its claim for this upon the fact that it is their belief that the inclu- 
sion of the new group, with its somewhat different labor problem than 
hand bags, makes it difficult for labor, as at present represented, to 
do an adequate job. 

My feeling is that there is no need for a second labor represen- 
tative on this Code Authority. In some instances, notably Killinery, 
I am delighted that there are two labor representatives and in the 
main it works extremely well and much of value comes from those two 
men. Because of the disrupted labor situation in hand bags and the 
growth of the Communist element.., I. do not believe it wise to stir up 
the troubled waters at this time, by the appointment of a second labor 
representative. , 

Some time ago, I sent forward a recommendation ,with respect to the 
appointment of nea men u^on this body. The letter was sent to either 
Colonel Berry or Leigh Ore raid acknowledgment its made* At about the 
same time By-Laws were approved and upon the insistence of the Legal 
Division the use of alternates, which had been customary, was discon- 
tinued. The lack of approval of these new nrmes is slowing up the work 
of this body, because one cannot be certain of a quorum at a meeting on 
account of the small number of men qualified to sit. I wonder if it 
would not be possible to hasten the arorov, 1 of the names submitted. 
I urge that this bo done. I realize that these men will only hold office 
for a short time, since within <* ,v .' . r sixty days a new Code Authority 
will have to be submitted to you for approval. 

The meeting adjourned about 11:15 p.m. 

Very truly yours, 

/s/ 0. ¥. HjARSOIT 

o. t/. pharsok 
AHiiiTisTauTio:; iumnn 
oyp/cB 



9811 



-305- 

Nati oriel -Recovery Administration 
45 Broadway, N. Y. C. 



March 8, 1935 



Colonel Welter Mangum 

Deputy Administrator 

National Recovery Administration 

Washington, D. C, 

In re: Ladies Handbag Code Authority Meeting 
Thursday night, March 7, 1935 

My dear Colonel Mangum: 

Three outstanding items came up for discussion at last night's 
Code Authority meeting. 

The first is the constantly recurring question on the part of the 
Code Authority with respect to the stay granted sometime ago to the 
| Virginia Art Company. I don't know whether you are familiar with the 
I situation. Briefly, it is that this company, through the good offices 
of Senator Glass obtained a stay on the provisions of this Code with- 
out any knowledge on the part of the Code Authority. They have always 
objected to this situation, and constantly point out the serious harm 
that is being, done to the Industry by the Virginia Art Company being 
permitted to carry on ^hat they consider a ruinous wage and hour 
schedule. 

Again the Code Authority voices its solemn protest against this 
situation. The Code Directors informed the Code Authority that Colonel 

Berry had refused to re-open the natter, and therefore, there was - 

nothing they could do about it. I think myself, the matter was not 
handled in its early stages strictly according to Hoyle. I believe' 
this early action was taken by Mr. Barr when he was the Assistant 
Deputy in charge. However, I am not certain about that, 

fc I wonder if there is anything that can be done to straighten out 
the matter, because it is subversive of good order end discipline. 

The second most important matter was that of the budget. 'The 
Code Authority accepted the report end recommendation of the Budget 
Committee, and within the next few days, I expect to send forward with 
my approval the new budget proposal. At that time, I will take occasion 
to com ient in some of the particular items included. 

In the meanwhile, I do want to specifically draw your attention to 
this. The old budget was set up on the basis of roughly $135,000,00, 
A certified auditor's report shows that in the nine months life of the 
budget, they expended a "trifle under $73,300,00, and' as a result they 
have today a cash balance of approximately $42,000,00. The care 
exercised by the Finance Committee and the Code Directors, and particu- 
larly the Code Directors, is a pretty good answer to one of the state- 
ments made in the Senate during this past week as to Code Authorities 
being a "racket". 



9811 



-306- 

It was unanimously agreed last night that at the close of the fiscal 
year, March 25, 1935, $30,000.00 be returned to the Industry, pro-rated 
according to each unit's payment to the Code Authority, This I feel is 
an excellent move, and of course, will make a good impression upon 
the members of the Industry. 

The third matter of moment, although not so important in itself was 
the time and pl-'ce for the next Cede Authority meeting, Ihis will be the 
annual meeting, and while there was some division of opinion based on the 
fact that members of the Industry might misconstrue the move, it was felt 
that the meeting should take place in Atlantic City, I told the Code 
Authority that there will be no objection to their having it in Atlantic 
City, provided, of course,, that there will be no undue expense incurred* 
I believe, however, that unless something was to be gained along the 
line of their being able to quietly sit down and consider depressing 
problems, there was not much point in going to Atlantic City, and that 
if the expense that would be involved were not so great, a better place 
would be Chicago, since it would have a good effect upon the Bag Industry 
operating in that center. 

In this general connection, I am concerned about the set-up of the 
Code Authority, Tnis -present Code Authority's term of office expires at 
the end of this month* Under the Cuin, certain associations were recog- 
nized. Since tne Code was written, those associations have retired from 
the field agreeing in so far as ps-sible to consolidate their membership, 
in what is to be known as the Lao.ies 1 Handbag institute. Since that 
Institute is not yet properly organized, it is my belief that it would 
be wise to continue the present Code Authority in office, until the ex- 
piration date of the Act, *>eiore that time arrives, the Institute will 
lie properly organized and we tnen can see whether it 'should be recognized 
as the proper agency to determine the membership of the new Code Authority* 

The Industry at this moment is in a cense at the cross-roads, and 
it is for politic reasons that I counsel you, if it be possible to con- 
tinue the present Code Authority for the period named above. 

Sometime ago, I wrote asking you to nush forward the approval of the 
additional membership. We are still constantly faced with difficulty in 
obtaining a quorum for the various meetings. I wonder what is delaying 
this. I should like very much to see this approval come through together 
with your following suggestion above, with respect to continuing the 
present Code Authority, 

Changes made by you and approved by the Code Directors with respect 
to two or three of the amendments proposed were formally approved by the 
Code Authority. 

Very truly yours, 

/s/ 0, W. PEARSON 

0. y, PEARSON 
Administration Member 

0WP:LB 



-307- 

MTIONAL hlCOVEBY ADMINISTRATION 
45 Broadway, N. Y. C. 



April 5, 1935 



Colonel Walter Mangum 
Deputy Administrator 
NRA Textile Division 
Department of Commerce "building 
Washington, D.C. 

Subject: Ladies' Handbag Code Authority Meeting held 
April 4, at Waldorf-Astoria, Hew York, N.Y . 

Dear Colonel i;angum: 

Starting out to be more of a social evening and celebration of the 
first annual meeting of the Code Authority the meeting really developed 
into a lengthy, somewhat troublesome affair. 

Before touching upon the troublesome problem presented let me first 
clear away the routine matters. 

There was presented an annual report of the Chairman, Secretary, and 
Treasurer.- These reports are informative and I suggested that they be 
properly edited, put into good shape and whatever charts may be necessary, 
and proposed that all of the material be published, circulated to each and 
every member of the industry as well as the Administration in Washington. 

The Virginia Art matter was brought up again and the Cod. e Authority 
acceded to your wishes as conveyed to them by Mr, Mitt en thai and there it 
was allowed to rest. 

Labor was rather articulate and while agreeing that the Code and the 
Code Authority have been of material help this past year, they have fallen 
far short of their possibilities. Labor representatives seemed to feel 
that it was the province of the Code Authority to help labor organize the 
industry, I took occasion to point out the necessity of an exercise of 
'patience in these matters and it was not the province of the Code Author- 
ity officials to play a part in the unionization of factories and shops. 

The troublesome matter referred to above is that of the action of 
Morris White who prior to his failure for $19,000,000 some three years 
ago was known as the great builder. After his failure he succeeded in 
obtaining a large sum of money from the ETC with which to start over again. 

Apparently as a matter of expediency he has developed into being the 
great destroyer. Jor ' a long time he took the position that he was above 
the law and he undoubtedly violated the Cede in every respect possible- 
in fact, taking a keen delight in showing all and sundry that he was above 
the law; that he was' a little better than anybody else because of his 
ability to get the inside track on Government funds. During the last 
several weeks he has been building a tremendous stock of handbags made of 
leather wh'ch I suppose normally would sell at better than a $2,00 average 
and is now in the process of dumping them on the market so that they can 

9811 



-308- 

be resold at somewhere around 80j£. In any event at less than $1,00, 
Since we are at the beginning of a. new season you will appreciate how 
destructive this is, not alone from a manufacturers point of view but 
also irom the retailers' since it of necert;ity depreciates the value of 
all stocks on hand. The people particularly hit are the $l o 00 bag 
manufacturers, whose products are largely made of artificial leathers. 

It does seem too bad that the manufacturer can on the one hand 
borrow operating money from our good. Uncle Samuel and on the other hand 
flout the law through practices that are wholly destructive. Of course, 
the industry is particularly concerned because of its possible effect 
upon the white season fast approaching. Due to the lateness of Easter 
it will only be a week or two after that date before the bag industry 
will be into the new white season and with such tactics there is apt 
to be a considerable mortality on the part of bag manufacturers, for 
obviously they canrot compete. 

In a round table discussion this morning with Mr. iicCarthy of the 
Consumers Advisory Board now stationed in I ew York, the thought was 
advanced that possibly through the NBA Liason Officer the matter might 
be brought to the attention of the Federal Trade Commission or the RFC 
and some steps irright be taken to put s stop to this demoralizing condi- 
tion. It certa. 1 'i_y w^ 1 : id be a great feather in your cap if some quick 
action could be obtained. 

The Ladies' Handbag meeting adjourned at midnight. 

Yours very truly, 

/s/ 0. ... PEARSON 

0, »« PEARSON 

. Adrni ■;. j, b b ra tr-n. Memb er 

P, S. I understand the industry is tendering a banquet to Messrs. 

Mittenthal and Eerkowitz on April 30 P-nc they are hoping that both Mr, 
Vincent and y,»urself will honor them by your presence that night- 
Invitations will go forward to you very shortly. I know it is a tax 
upon you two gentlemen to ask your pre;; rce but I honestly believe it to 
be a politic and wise thing to do, After all these men have made a great 
struggle this past year to : pull themselves up by their boot straps and 
they would have a very high regard and respect for you two gentlemen. 
I would like to see you, lend them encouragement in the manner I suggest. 

0. 8Y P. 

F3*S . I think I shall have to be in '.ashington next 'Thursday at which 
time I hope to have an opportunity of seeing you, 

0. '.?, P. 

0WP:MKF !"""'.", ■ 



9811 



NATIONAL RECOVERY ADMINISTRATION 
45 Broadway, N.Y.C. 

July 10, 1935 

MEMORANDUM 

' . LADIES' HANDBAG INDUSTRY 

INDUSTRY 

The Ladies' Handbag Industry as an American industry dates back 
about 50 years. During the first 20 years there was scarcely more than 
6 manufacturers at a time making handbags and all of these made in 
addition a full line of leather goods. In those early days the industry 
as known today, was scarcely a separate industry. 

At the present time there are engaged 379 manufacturing units 
with 146 contractors and approximately 15,000 workers. 

The estimated capital investment is about $10,000,000 and its 
total volume is about $40,000,000. 

The year 1927 was probably the big year of the industry, both in 
volume of sales and profits. At that time it was mainly centered in 
x, ew York and to a great degree almost wholly a. "craft" industry. 

As a result of the soft living and thinking of the lush years, 
1925 to 1929, troubles with labor began to develop so that first one and 
then other manufacturers decided the time had come to get away from the 
big city. This was the beginning of the migration of the industry from 
New York, and led to the general exodus in 1935. Today at least 75$ of 
the industry is scattered through the New England States, New Jersey, 
Pennsylvania, with two or tnree factories in the South and some in the 
Middle West. Prior to the scattering oi the factories and leading up 
to it, a general strike was called in the late sumuer and early fall 
of 1934, This strike was abortive. 

It was because of this first migration that so much trouble and 
bitterness ensued in the early days of the FRA. Hatred almost grew 
up between the out-of-town manufacturers and the New York group. 

TRADE ORGANIZATIONS 

Before those first ERA days there had been two major trade organi- 
zations in existence, the older one oeing the usual trade organization 
type, general in its scope and, of course, ineffective. The other, a 
smaller organization concerning itself with labor questions and agreementsi 
During the days of code writing, a third powerful organization was set 
up, the members of which consisted of out-of-town manufacturers. It was 
evident during that time, and at the presentation of a code to the 
Administration and curing the subsequent hearings and conferences that the 
New York group, still being in the ascendancy, was bound to accomplish 
the elimination of the out-of-town manufacturer or at least place him 
in a position where he could not longer capitalize cheap labor and long 
hours. The winning of the fight by New York resulted in a sharp division 
so that when the Code Authority was finally set up, it was an armed camp, 
9811 



. . -310- 

CODE AUTHORITY MANAGEMENT 

In the first days, after I inaugurated tiie Code Authority, it be- 
came seemingly impossible to bring about peace and fortunate it was that 
the industry had selected men to head up the Code Authority work in the 
persons of Messrs* Abraham Mittenthal and Max Berkowitz, assisted by 
Maurice ivlossessohn. I say it was fortunate that these men were selected 
because they had been connected with the industry for many years, had 
vision, level heads, integrity and patience and thus were able to carry 
on successfully. The first two named owned their businesses as manufac- 
turers, one in his business looking after distrioution and understanding 
those problems, and the other a production man, understanding all the 
twists and turns of factory oneration. Mr, Mossessohn had dealt with 
the industry through the Associations and had obtained therefrom a broad 
understanding of the personnel of industry, their peculiarities and a 
knowledge of how best to approach and handle such men. 

INDUSTRY PEACE 

After the Code Authority had been in operation for two or three 
months, I made up ray mind, that if possible I must bring about peace in 
the industry and one night at a Code Authority meeting arbitrarily 
adjourned the regular meeting at 1Q,:.U0 in the evening telling the members 
that, we would reconvene as a meeting of ind.ustry, and that I was prepared 
to sit with them all night and all the next day if necessary, to find a 
ground upon which all might st?nd to the end that they would accomplish 
the good that all agreed could come under the code. That, night session 
lasted until nearly 5:00 in the corning. It was later followed by 
numerous conferences with various groups and sometime later a. further 
conference took place on the train enroute to a public hearing in 
Washington. This conference was continued in Washington at the Carlton 
Hotel, adjourning at 3:00 the next morning and peace agreed to and signed. 

Unfortunately, peace was not declared between the industry and 
labor. Included in the original code was a clause which called for a 
definition of semi-skilled labor. Realizing the difficulty of determin- 
ing this point, I personally visited numerous factories in and out of 
New York to see whether I could reach a conclusion as to where to draw 
the line as to skilled, and semi-skilled labor. Having found it impossible 
to reach a conclusion myself, I so informed the then deputy and it was 
unfortunate that at the public hearing referred to above the Assistant 
Deputy in charge either did not understand or seemingly found himself 
unable to appreciate the difficulties of writing a conclusive definition 
and insisted one must be written. This led to increasing the bitterness 
as between the manufacturer, labor and the Administration, Notwithstand- 
ing- this, the Code Directorate kept. its head, its feet on the ground and 
the steering of a fair course, and although a general strike was called 
lasting some 60 or 90 days, succeeded for the year 1934 in bringing the 
industry into a better financial condition than it had enjoyed for many 
years 

FINANCE 

The financing of the Cede Authority was based upon assessments and 
while this was a label industry, labels were sold at cost. The financial 

9811 



-311- 

operations '-'ere so veil conducted that at the end of their first year 
the Code Authority was able to declare a dividend and return to the ind- 
ustry 25% of the collected assessments, which assessments were obtained 
from 98?t> of the industry. 

The first year's assessment basis was 1/3 of Ifi, For the second 
year this was reduced to l/4 of 1^ 



I "A 



EMPLOYEES ENGAGED 

The. total number of employees engaged by the Code Authority were 17 
and the Directorate were satisfied with a very modest office layout. 

COMPLIANCE 

This "chase of the work is one that will always stand out because 
of the patience, forbearance and understanding with which it was conducted. 
Finding complaint as to inability to live up to wage and hour provisions, 
examination was made of factory practice and it was invariably determined 
that management was at fault and the right way pointed out to the erring 
manufacturer so as to make possible without punishing his pocketbook to 
meet the scales reouired. In the large majority of cases this was 
appreciated and followed so that the percentage oi compliance was always 
high. In the few outstanding wilful non-compliance cases the usual rule 
of obtaining influence was followed and invariably restitution obtained, 

STATISTICS 

For the first time in the history oi the industry, the Code Authority 
machine began to collect statistical information, all of which material 
has been filed with the Deputy Administrators. Had the Code Authority 
continued it cannot be doubted that the industry would have found many 
answers to problems long sought but heretofore unobtainable, here again, 
will be one of the difficulties under their voluntary cods set-up for 
without force of law I question whether industry will divulge important, 
necessary facts and figures upon which officials can base constructive 
conclusions. 

CODE AUTHORITY PERSONNEL 

The original Code Authority personnel never changed. However, since 
the code provided for three extra members the industry insisted in public 
hearing that the Administration Member should appoint these men, subject to 
approval of the Administrator, rather than leaving appointment in the hands 
of industry. The names of these three men were not submitted until late 
in 1934 or early in 1935 and not approved until two or three weeks prior 
to the handing down of the Suoreme Court decision so that the three never 
really functioned. 

COHtilTTSES 

The Labor Complaints Com nit tee was set up but never approved. 

The Trade Practice Complaints Committee was approved but never really 
functioned because, due to the diligent and unusual manner in which the 
Code Directorate operated through which they persuaded manufacturers of 

9811 



the error of their ways when violating .qode provisions, such complaints 
were adjusted to the satisfaction of all.: • ; ■ ■ 

CODE PROVISIONS 

' , ... : i ..... • ■. 

A great mistake was made in the order, approving this code, wherein 
it was provided the Cod e Authority should present to the Administrator 
a definition of the term "serai-skilled" employee. Apart from the impos- 
sibility of this determination it lead to constant trouble between labor 
and employer. 

Paragraph 1 of the definitions was not as clear and as oomprehensive 
as it should have been. This, of course, was largely the fault of 
industry itself. 

■ ?/age and, hour provisions were, to a large degree, satisfactory 
except for Section 2, Article IV, which was stayed under the order 
approving the code. 

In so far as trade practice provisions were concerned I think it 
was useless to include, as was dor.e in this and many other codes, 
provisions respecting return of goods and commercial bribery. Such are 
almost impossible of enforcement since they cannot be properly checked, , 

A i* r ell~Gonsidered. tnoughtful attempt was made with respect to the 
homework problem. I do not need to enlarge upon the great difficulties 
surrounding this particular ouestion. However, the intelligence of 
the Code Directorate was brought to bear in such a manner that definite 
progress was being made toward the elimination of -some of the most .glaring 
evils, underpayment of, labor be.i.ng the most notable*; My own opinion is 
that this subject can best be approa.chjd febrough the agency of various 
women's organizations of the countr/, looking toward the time when they 
will insist that, all sources of supply mark :opds to show their origin and 
check such to determine mill conditions,, Of course, to carry this to a 
successful conclusion vou '- t ou1q need an act oi Congress or of the various ■ 
state legislatures providing for the 1' belling of all merchandise,. I 
don't mean that such labels ^oulc oi necessity carry trade names, but 
have identification marks that would make easy the disclosures of the 
point of origin. Marking is at nresent recuired upon all imported goods 
and I see no reason why it should not be Ujpon articles of domestic 
manufacture. 

LABOR 

During the last t-"0 month's of 1934 and the first three or four months 
of 1935 a change began to take' place in the complexion of the labor union 
operating in this industry. Apparently, trouble had been brewing in the 
union for a consiCi.err.ble period of time and since the general strike was 
pretty much of a stalemate, if not a total loss, the internal fight oame 
out into the open resulting in a complete over-throw of the old union 
management,. I was informed that the con:iunists had definitely got into 
the saddle and this made the situation as between laloor and industry more 
difficult than ever. 

As a result more manufacturers left Tew York and a number of such 
were hailed into the courts and before the Regional Labor Board for 

9811 



-313- 

violaticn of 7 A. In practically all of these cases the manufacturers 
were found guilty but nothing happened as there seemed no power to en- 
force decisions handed down. 

EFFECT 0? CODE 

An interesting sidelight on the mental condition of the industry 
late in 1934 is "best illustrated by relating an incident that happened 
just prior to Christmas of 1934. Two manufacturers who had never been 
real supporters of the code, happening to be in Washington and finding 
out that I -'as also there called me on the telephone to ask if they 
might see me for a few minutes that evening. This I agreed to and was 
told by these men that they wished to apologize for any sins of 
omission or commission respecting the code on their part, that they 
were about closing their books for the year and were delighted to be 
able to say that in their opinion the code had served them to such good 
purpose they were going out of the year in black ink and felt further 
that many other members of industry were of the same opinion as them- 
selves. 

Having reached the point -here at least 95$ of the industry 
were thoroughly sold on the value of their code and its administration, 
the industry was literally stunned when the Supreme Court decision was 
handed down in the Schechter case and today are moving heaven and earth 
to get the industry to voluntarily agree to a code of their own, a copy 
of which I attach and which is on file with the federal Trade Commission. 

I am told that 85$ of the industry have already assented in writing 
to this document and for the rest the old Directorate, still maintaining 
an office on a very modest scale, are beginning to exercise pressure to 
bring about conformance through local banks, clergy and chambers of 
commerce or boards of trade in various localities in which such manufac- 
turers are situated but I recognize the great difficulty of enforcement 
even with a 100$ assent without the support of some governmental agency. 
In passing I may say that any steps taken subsequent to the Supreme Court 
decision have been closely scrutinized and in so far as possible opinions 
sought from the federal -L'rade Commission as to legality. 

Respectfully submitted, 

/s/ 0. V, PEAHSON 

0. ... PEARSON 
Administration Member 

0V.F MS.F 



9811 



Erie: Oil Bcmbc 'rfo-rir -(^ Part a J 



9811 



-315- 



EXHIBIT "0" 
Part 1 



PLAIT FOR COlfTROI 0? HOF-ETORK 

AND 
ABOLITION OF CHILD LABOR 
FOR THE 
BEAD BAG INDUSTRY 



9811 



~51S - 

REGISTRATION BY I :MU?AC TURERS 

Every manufacturer or contractor employing homeworkers on hand- 
beading or crochet~b9ading must register immediately with the Code Author- 
ity the narno and address of such workers who ha-ve been in their emoloy 
during the last year to whom work is given out to be mode in the home. 
No homework can be given out to any h.a.'!SWOrker unless such homeworker is 
registered with tha Code Author:' Ly. ■ ., 

REQ-ISTRATIOII IT Ff. .^WORKERS 

Each homeworker must register vj bh tho Code Authority the name and 
address of the manufac urer or contractor for whom he or she is doing 
homework, immediately upon being given such homework. 



submiss io'jg of de jic-n 

Each manufacturer, before giving o rt a bag to be made to a home- 
worker, must fire.;, submit to tne C/ da Authority a sketch of the has, 
showing the dcjjgn and! a full description of the quantity and kinds of 
beads to be used, also r lub off of the bag in triplicate, also an es- 
timate of the tine required by the homewoi kar to do the crochet beading 
on the bag as submitted. Whenever necessary, the Code Directors may 
also reouire that a finished sample of the crochet beading accompany the 
sketch. 

Upon submission of the design, the Code Authority will determine 
the piece wCft'k price to be paid the homeworker, and a registration num- 
ber will be assigned to such design <-_ riTivuf ac rarer or contractor agrees 
to pay such homeworker the price so del 3± •..:;. :d tv the Code Authority. 
A manufacturer shall nave the right n protest an v pries set by the 6ode 
Authority, wnich in his opinion, apue.i... ■: to ba unfair. In case of pro- 
test so filed, the Code Directors will teat lie time rewired to make a 
finished bag bv a homeworker of average speftd and ability. The manu- 
facturer agrees to accept the result as final of any test so made. 

RL-CCT u.' T'oRhS 

Each manufacturer shall keep a record of everv job given out to the 
homeworker. These records shall be in triplicate form, approved by the 
Code Authority. One copy to be retained tr-> bhe manufacturer, one given 
to the homeworker. and a cop 1 '- sent to the Code Authority. This record 
must contain the name and address of the homeworker, the style number of 
the bag, the quantity and the price and the registration number of the 
bag. 

Each manufacturer shall keep records of all oayments made to 
homeworkers according to the uniform methrds prescribed by the Code 
Authority. 



*** 



9811 



-317- 
CHILD LABOR 

Ea.ch record of work --iven to a homeworker must have stamped upon 
it in red ink immediately above the point at which the homeworker is re- 
quired to sign for the work, the following words: "I agree not to per- 
mit anv child under sixteen years of age to perform any work on these 
goods. " 



CONTRACTORS 

Each manufacturer as far as is oracticable should not emplov con- 
tractors on crochet heading. Tf, however, such contractors are employed, 
the price fixed "bv the Code Authority for such homework is the orice that 
must "be said to the homeworker bv the contractor, and no contractor shall 
withhold anv oart of the orice fixed for such homework. 



COMPLIANCE 

The Code Directors, in order to maintain the minimum wage for home- 
workers and to orevent the employment of child labor in the industry, will 
enforce strict comoliance bv manufacturers rnd homowork^rs with the code 
for the industry. 



9811 



-v 10- 

^ ...... 

HOMETOBKER ' S iG-REEIvIENT 

Agreement between ■ . : -■ ■ , ■ ■ ■ home worker, 

and the Code Author itv Ladies' handbag' Industry. . . - \ . 

'! •. •••'.•.•■■■ : •• ■ '.•■', 

i agree to perform work on crochet beading on handbags in mv'home ■ 
in accordance wi+'i the rules and i' egui3.ti r ns established bv the Code 
Authority for the Ladies' Handbag \iidv.b iry . 

(1) I cgree that no child under sixteen years of age shall at any 
time perform any work on such gon&s as are given to me to be 
Eade in my nome. . ■• . ■ ■• . . 

(2) I agree to register immediately with the' Code Authority the 
name of the manufacturer or contractor who gives me work to he .• 
made in mv home. 

(3) I agree not to give back to anv >ersnn or persons anv nortion 
of the price :>aii to n:s for such homework. 

(4) I agree to work not more than forty (40) hours in any one week, 
and not more than eight (8) hoars in any one day, \ 

(5) I ag-ree .ioi; to ...accept, any. haad'-or.. crochet, beading t-o be made at 
home, unit, is ths price paid me for such work is the price fixed 
bv the Code Authority. 

(6) I agree not to accept any homework from anv manufacturer or con^- 
tractor unless such manufacturer or contractor has signed a com- 
pliance with the Code Authority of the Ladies' Handbag Industry. 

(7) I agree that I will not accept e.-_v homework, should there be anv 
contagioirs disease in m- r horns 

(8) I agree to permit an inspection c\ my home at an" time bv an 
investigator for the Code Authority for the Ladies' Handbag 
Industry for the puroose of determining mv compliance with this 
agreement . 

(9) The following are the persons in my home who are aualified to do 
woik on crochet beading: 

DATE OF LAST 
NA>!E RELATIONSHIP AGE WHERE BORN BIRTHDAY 



Signature 



Address in full 



Telephone Number 



9811 



-319- 

EX TT niT 
Part 2. 



December 19, 193" 



Mr. Leigh E. Ore 
Assistant Deputy Administrator 
Commerce Building 
Washington, D. C. 

Dear Mr. Ore: 

le are in receipt of a copy of the memorandum submitted by 
Mr. ~.osenz , "eig covering our olan for the control of homework. n e 
have noted carefully Mr. Rosenzweig's objections to the plan, and 
his reouest for further information on some of the joints covered 
in the plan. 

Hand-beading and crochet-beading are the only homework ooera- 
tions permitted by our code. There are about 3000 homeworkers who 
perform this particular work. Of this number, our industry employs 
about 3400 workers. These workers are scattered throughout six 
states and. about 200 communities. Hand-beading and crochet-beading 
are skilled operations, and' Can only be performed after more than 
a year practice, most of the good workers are those, who learned to 
do this work in their native countries and who never did this fork 
other than in their own homes. 

At the hearing of the Pleating, Stitching and 3onnaz and Hand 
Embroidery Code Authority held in Washington on November 20, members 
of that industry gave evidence that continuous advertising for hand 
and crochet beaders to work in the factory resulted in only a few 
workers applying. To be exact, the number was stated as sixteen. 
This has been the same experience of members of our industry who 
also advertised for crochet beaders to work in the factory. Very 
few such workers aooli'ed, the reason being that the workers are so 
widely scattered, that no factory whereever established would be 
convenient to any considerable number of workers. 

Tlie average time for the crochet beading of a bag takes from 
one to two hours for one bag, so that an average worker on crochet 
beaded bags produces in an eight hour day about four to six bags a 
day. The production ^eouired for an average manufacturer is at 
least sixty dozen a day and in the season about 120 dozen a. day, 
so that a manufacturer would have to employ 120 workers on crochet 
beading alone to produce 720 bags a. day, and in the season 240 
workers to produce 1440 bags, besides, lie must employ other workers 
who do cutting, operating and finishing on the bags. There is not 
a manufacturer of beaded bags who can establish a factory in a.ny 
locality in the United States r, nd obtain 240 experienced crochet bead 
workers on handbags who ai-e living within any convenient distance, 
willing to perform the work in the factory. The production of cro- 
chet beaded bags is so slow that overhead costs- would, be prohibi- 
tive if the work was performed, in the factory capable of housing a 
9811 



sufficient number of workers to produce the average renuired pro- 
duction of a single manufacturer. The unproductive period in the 
industry is about four months in the year. 

"'ost of the beaded bags are imported by retail distributors 
who sell direct to the consumer, so that the American manufacturer 
is not even protected by a Jobber's profit. The beaded 'bag indus- 
try in America, has not developed to any large extent, because their 
existence depends almost entirely in producing types of bags that 
are not competitive with foreign made styles, and just as soon as 
an American produced style has proven a good seller, it is sent 
abroad to be copied and then sold in the United States for less 
than the American made bag, Considering the unusual conditions ex- 
isting in this industry, it is apparent that if homework in the in- 
dustry ca.nnot be maintained, it would mean the complete abandonment 
of the beaded bag industry in the United States. 

The plan as submitted may not answer every reouirement of the 
WSA Homework Committee, but at least it is an attempt to keep the 
industry existent and to give to .these 3000 or more workers a living 
in accordance with the code renuirem'ents. 

Answering Mr.. Rbsenzweig's 'objections specifically: An inves- 
tigation was made of homework in the indus'try in accordance with. 
Section l r \ Article V of the Ladies' handbag Code. This investiga- 
tion was made jointly by the Code Directors and the Committee ap- 
pointed by the Code Authority. The' result of this investigation is 
contained in a brief, a copy of whicjl was submitted to the Adminis- 
tration sometime ago. The investigation included the testimony of 
manufacturers, contractors and homeworkers. Open hearings were 
held, which were attended by the. Administration Member and all other 
factors in the industry; ~nd also private hearings with homeworkers 
and contractors who gave oral and Written evidence. The Code Auth- 
ority approved the report of the committee and approved the plan 
which was proposed by the Code Directors to control homework and 
abolish child labor in the homes. The original plan included the 
grf nting of a special homework rate, on hand-beading and crochet- 
beading, in consideration for the promise of the beaded-bag manu- 
facturers to establish and maintain an agent or agency vuider the 
direction of the Code Authority to fix piece work prices so the 
homeworker could earn the minimum '"age rate of the code. This plan 
was presented at a hearing held, in Washington on July 9, 1934, at 
which Assistant Deputy Administrator 3a rr presided, but which" was 
never approved by the Administration. Pending the approval of the 
plan, compliance with the code wage rates for homework was difficult 
to obtain and the Code Directors did bring cases of non-compliance 
to the WSA Regional Board, 'but no satisfactory decisions were ever 
obtained. 

The present plan does not rely upon any voluntary cooperation 
by the manufacturers. Realizing that the homeworker was entirely 
without the protection of the code because they were employed chief- 
ly by contractors, the Code Directors began an investigation of the 
contractor, homeworker relations. They found in this the chief evil 
in the homework problem. It was customary for such contractors to 

9811 



-321- 

retain from 2~f r - to 40<S of the price ,-aic by the manufacturer for home- 
work. If homework is abolished these contractors will become the real 
manufacturers and scattered as they are, it would be absolutely im- 
possible to even locate their. workers, much less to get compliance. 

The jroposet plan aims to eliminate these contractors, . and if 
we can do so legally , we feel the success of the plan would be en- 
hanced considerably. We are. st'riving\.tc make the manufacturer deal 
directly with the homeworker, and through registration by both manu- 
facturer anc the homeworkers, we can ,iut into effect our plan to 
establish the minimum wages rates of our code for the homeworkers. 

As a practical problem, the abolition of homework in this in- 
dustry would immediately create a system of bootlegging in homework, 
accompanied by all the vicious and racketeering methods common to 
prohibition. . ■ : . 'ulioirieworkers ' would, buy their own beaus and com- 
plete the bags, and sell at prices that no manufacturer could meet. 

Answering the specific objection reised 'ay Mr. Hosenzweig: The 

piece work prices will be fixed on the following bases the number 

and kind of beads that go into p.. bag are determinable. The basic 
price will be fixed according to the niajiber of beads and the kind of 
beads. The irice is calculated' according to the number of strings 
of oeads. Only in case of unusual design, a test of time required 
to finish such a design will be made. The Code Authority will employ 
such workers or workers on their premises to .actually make the sample 
for the .uipose of testing the time required. The Code Director will 
then fix the : ;>rice for that particular design. The Code Director 
happens to be thoroughly experienced in the making of beaded bags. 
No manuf; cturer will have an opportunity of having his own workers 
do the testin :. 

We accept the suggestion made by I.ir. Rosenzweig that the home- 
worker a.s well as the manufacturer shall have the right to protest 
any price set by the Code Authority. In case of such protest, the 
Code Directors will cause to be made an actual test of the time re- 
quired to make the article in question. 

In the matter of child labor, the record in the Administration 
will show that in another branch of our industry (braiding of leather 
bags) the Code Directors were convinced that child labor was being 
employed, and without hesitation requested and obtained and administra- 
tive order abolishing homework in that branch of the industry. If the 
Code Dire "tors found that child labor is being employed in the making ' 
of beaded bags, they would just as quickly abolish homework in this 
branch ox the industry as they did in the other branch. 

The natter of contractors gives us the most concern in this plan, 
mainly because of the legal status of the contractors. If the Code 
Directors are informed that they have the right to abolish contractors 
in the beaded branch of the industry, the problem of control of the 
whole plan would be much more simple. In the plan wo only said: "as 
far as practicable" contractors should not be employed. The Code 
Directors would welcome a legal opinion covering this matter of con- 
tractor relations with manufacturer anc homeworker. 

. 3811 



Under our plan, the contractor is required to register with the 
Coue Authority the name of each homeworker employed by him. The 
contractor is also required to sign the homework agreement the same 
as the manufacturer-. To meet the objection of Mr. Eosenzweig, we 
are willing to insert an additional clause in the agreement which will 
mal:e the manufacturers directly responsible for what the contractor 
pays the horaeworker. This clause will read as follows: 

"An;-" manufacturer in the industry enrol oy in""' a contractor 
or contractors for work to be performed .on hand-beading 
or caro'chet-beading shall be responsible for the difference 
between the price paid by the contractor to such home- 
worker and the price that the homeworker is entitlec to, 
receive, according to the Code Authority's price fixed 
for such homework. " 

'.Te also accept the sup estion of Mr. Eosenzweig to change the 
requirements for keeping "record forms" so that it will also include 
the contractor. The clause will be changed to read: 

"Bach manufacturer or contractor shall keep a recorc. of 
every job given out to the homeworker, etc." 

In the matter of compliance, we realize that close supervision 
of the homeworker would oe difficult and costly. . ¥e expect, however, 
to exercise close supervision over the manufacturer and his contractor 
and to obtain their strict adherence to the plan. We have only 14 
manufacturers in the industry, all located in Mew York. , The record 
forms are bein,:, prepared by the Code Authority and will be made uni- 
form for the manufacturer and the contractor. The Code Authority 
will make frequent tests of homeworkers compliance throu, h visits 
oy our inspectors in the homes of the workers. 

We did not provide for a manufactuer' s or contractor's agreement 
as well as a homeworkers, as we felt that the manufacturer and the 
contractor were both .members of the industry and contractor were both 
members of the industry and could be held for a violation if they 
failed to comply with any provision of the plan. If it is the opinion 
of Mr. Eosenzweig that separate agreements should be signed by the 
manufacturers and contractor;, we shall have then co so. 

We agree that the paragraph in the homeworkers agreement pertaining 
to <-0 hour:: of work cannot be made effective. we have only hoped that by 
inserting this provision the homeworker *-ould feel restrained to limit 
her hours o, work. Knowing that she had signed such an agreement, might 
have the desired effect. The fret is the individual homeworker, who is 
most frequently the housewife, rarely gets an opportunity to devote more 
than 8, hours in a day to her homework. 

We have attempted to answer the objections raisec by Mr. Eosenzweig' 
in his memorandum against oui plan for the control of homework and 
the abolition of child labor. Frankly, we str-'j that the plan is an 
experiment. However, it is in the hand 1 -, of the Code Directors who are 
experienced in the industry and know the difficulties that must be 

9811 



-323- 



surmounted to make the plan workable. We feel that every opportunity 
should be accorded the Code Authority throu h the Code Directors to 
give this plan r trial, with the as-.urence thrt if after a reasonable 
time the ;lp.ii is found to be unwor? :aole, the Code Directos will so 
notify ;ou and shall then "be prepared to accept any decision of the 
homer-orh committee for the totr-1 abolition of homework in the incustry. 



Very truly yours, 



CODE AUTHORITY 
AM:AS DADIIS 1 BAITDBAG IEDUSTHY 



A. Kittenthal 

Coop Director 



9811 



-324- 

exhibit o 

Part 3 
EOiJBfOBK ■ 

Memo Prep' red By A ivlanuf acturcr Por 
June Plearing 



The "osition of the beaded bag industry in America is one that 
requires special consideration because its competition is not with other 
American made products, but ■ Imost entirely with a product that is m-ade 
in foreign countries, without anadequate tariff to protect the American 
made product. 

The system of making beaded b \gs in Japan , Belgium, Czechoslovakia 
and Prance, where most beaded bags are made, is too well known to the 
industry to explain in detail. They are made entirely in the homes and 
the workers earn throe to five cents an hour. A tariff of 60$ only 
adds two to three, cents vn h our making the total five to eight cents an 
hour, plus another 15$ to 20;' for freight and other overhead charges. 

It is obvious that the beaded bag industry c --'.not exist under the 
present wage rate established by the Code and will soon become extinct 
as an Americ ,n Industry. At present, the work is given out to home 
workers, the industry employs abuut 7000 such workers, in a few hundred 
cities and villages, in ten different states. A visit to many of the 
homes of these workers will bear evidence to what the income from this 
home work means to these families, frequently it is the only source of 
income, in many cases it is added to the meager earnings of partially 
employed members of the family and affords the few luxuries they enjoy. 
Without this home work, many of these families would be found on the 
city charity payrolls. 

Even before the effective date of the Code, March 26, the prices 
paid for home work, even though admittedly low, it was regarded as a 
blessing to these workers, who could not because of family or physical 
reasons leave the home to work in a factory, even if such a factory 
could be established in the locality of their homos. 

The beaded bag industry has proposer- to the Code Authority a plan 
that will assure to these workers a rate of './age .about two and on'- half 
times greater than they hav been able to earn heretofore. By this plan 
no manufacturer may take advantage of the absence of bargaining power 
by an individual home worker. The plan will be supervised by the Code 
Authority, and. enforcement of the wage rate of 25i an hour put under the 
compliance division of the Code Directors. Tao plan provides that the 
beaded bag manufacturers shall appoint an imparti 1 ncrson or agency to 
be designated by the Code Authority, to whom all articles given out to 
be made by home worker? will first be submitted for the fixing of a piece 
wbrk price that will result in a wage not less than 25^ per hour to a 
heme worker of average ability. That failure on the -oart of a manufacturer 



9811 

mi 



f325- 

to submit any item to the impart i .1 .; ency shall be considered non- 
compliance with the Code. 

If you consider that a worker in ci : ht hours is only capable of 
finishing throe be'\dcc bags that retail at 31.95 or ..'.95 each,, and that 
the manufacturer must produce at least five gross of these bags in an 
eight hour day to maintain a volume of sales sufficient to support his 
selling ncl administrative overhead, you will realize that to produce 
750 uiits he would have to employ 240 such workers. To house 240 workers 
requires at least ,?0,000 square feet of floor space. Even if it were 
possible to establish a "lant in any locality convenient to .340 such 
workers, the attending overhead would make it impossible for the manu- 
facturer to compete with the imported product and at the same time pay 
the workers three times as much as is paid for the imported article 
including the duty. 

The Beaded Bag Industry because of the kind am nature of the com- 
petition, .nd for the reason that it is unprotected from this competition, 
deserved and requires that it be granted a continuance of home work and 
a preferred rate until such tine that the government grant to the in- 
dustry increased protection through an increase in the tariff on beaded 
bags. 

An application for such relief has been made, in the meantime, 
these 7000 workers must be provided for by an industry who is trying to 
do its part. to make it possible for Aneric n workers to do this work. 



9811 



-326- 

EX HIBIT 
Port 4 

C II T 3 IT T S 
*** 

Letter of Transmittal 

Report of Committee on Homework 

Majority Report 

Minority Report 

Report of firm of Kaplan & Gordon 

Report of Meeting of Importers 

Report of Contractors 

Administration Member Ruling on Labels 

Protests against Ruling on Labels 

Requests for Official Ruling on Labels 

Notice of Stay from Pleating, Stitching & Bonnaz & Hand Embroidery Code 

Recommendation ff Code Director 



9811 



"Oo'7*~ 



Lay 14, 1934 



Dear Member: 

lTrlnl° B i^ herewitl1 « copy of the resolution massed by 
the manufacturers of beaded bags at a meeting held on May 7 

thT'/T/^r 21 memberS preSSnt " — voted in favor of 
the resolution, four against, three not voting. 

I am also enclosing a co;?y of the minority report filed bv 
concerns who are mostly importers of beaded bags a s o a 

bS y iSut^ diVidlaal "*"< *» * -ufacturfr of treaded 

witrtV ^, 8 -"^ SCnt f ° r the "^° SG of familiarizing you 
wi tn tne particular problems of this division of the industry 

w 11 belSenXranr 8 1 " J? ^ M ^ th * »«^» 

presented at tne next meeting of the Code Authority. 

Very truly yours, 



Code Director 
Ladies' Handbag Industry 



9811 



-328- 

The "beaded "bag manufacturers, a division of the Ladies' Handbag 
Industry, is now operating under the Code of Fair Competition for 
the Industry. There are about 25 manufacturers in this beaded bag- 
group employing about 5000 workers who do hand-beading, hand-crochet- 
ing or hand-embroidering, and the work incidental to the finishing 
of a bag. 

Of the total number of workers employed in the industry not more 
than 500 are employed in the factories, the other 4500 are employed in 
the homes to whom work is given to be made uc into bags or parts of bags. 
This homework being permitted under Section 10 of Article V of the 
Code. The Code, however, provides that such homeworkers shall be 
paid at the same rate as factory workers 35^ per hour. 

The beaded bag manufacturers find the greatest competition from 
foreign made beaded bags, imported chiefly from the countries of 
Belgium, Franco and Czechoslovakia. In these countries the workers 
who do this work also do it in the homes, and are paid on an average 
of five cents an hour. The duty on these beaded bags in now 60$, ..to 
which may be .added freight, insv.rar.ee and other charges amounting to 
another 10$ so that beaded bags in these countries are produced at 
a rate equivalent to 8§ cents an hour. It is obvious from the very 
outset that American manufacturers, making the same or similar 
beaded bags operating under the Code of the Industry and paying at the 
rate of 35(£ an hour cannot long survive. 

After a trial of six weeks, these beaded bag manufacturers are 
convinced that it is futile to try to meet this. competition, and that 
the industry must be abandoned as far as trying to make such bags in 
the United States under the present wage provisions of the Ladies' 
Handbag Industry Code. Retailers and Jobbers in the United States 
finding that the products of American manufacturers are not comparabel 
in value to foreign made beaded bags have ceased to buy American made 
bags and are now importing their own beaded bags directly from the 
manufacturers in the foreign countries mentioned. These direct im- 
portations because of their greater values, have destroyed the American 
market for the American bead-bag manufacturers. 

The workers employed by the beaded bag industry, who number more 
than 5000, find themselves unable to obtain this work, and at a time 
when the demand for beaded bags is greater than normal. These workers 
because of their inability to work away from home depend largely upon 
such earnings as they can obtain at homework7" Their Ability to 'add to 
the insufficient earnings of other members of their family, did a great 
deal to make these people independent of public aid. Until the Code 
for the industry became effective, these workers were being paid at a 
rate far below the present 35^ per hour. But the rate of wage was 
forced upon them through competition with the foreign made goods. 
To preserve the beaded bag industry in the United States, and to furnish 
enrol oyment to these 5000 workers who defend uoon this industry for a 
large portion of their livelihood, it is urgent that the manufacturers in 
the industry be granted the relief they ask for in this petition. 



9811 



-329- 



1. - EESOLVH) that the Tariff Imports Division be and is hereby 
petitioned to increase the duty on beaded hags, as now defined in the Act from 
60^' to 80$ and that such increase become effective at the earliest possible 
date. 

2. - RESOLVED that sending the action of the Tariff Imports Division 
in granting the relief asked for, that the Code Authority Ladies' Handbag 
Industry be and is hereby petitioned to grant a minimum rate of 25<i an hour 

to all beaded bag manufacturers for work done in the home of the workers, when 
such homswor' " is permitted by the Code. 

The present minimum rate of 35<jf per hour we are sure is resulting in 
non-compliance with this provision of the Code, because it is impossible to 
trace this homework into the homes of a thousand workers scattered in the 
rural districts of at least ten states. 

The bead-bag, manufacturers realize that even with a rate of 25i per hour 
they can only hope-to compete on some items, while with other items it would 
still be impossible to meet the foreign values; however, the industry feels 
certain that comoliance with the labor provisions of the Code can be made 
more effective when the manufacturers of beaded bags realize that they are not 
threatened with total extinction. Furthermore, the manufacturers in order to 
obtain strict compliance of the Code, pledge themselves to establish and 
maintain an impartial person or agency to be designated by the Code Authority 
to whom all articles given out to be made by homeworkers will be submitted 
for the fixing of a piece work price that will result in a wage to an average 
worker of 25<i per hour. Failure on the part of a manufacturer to submit an 
item to the impartial person or agency will be considered non-compliance with 
the Code. 

All wor v given out to be made in the homes of workers will be controlled 
by the impartial person t agent through rules and regulations to be established 
by the members of the beaded bag group. 

The beaded bag manufacturers request the Code Authority to consider this 
vital problem for the industry and that it grant the exemption it asks for 
until such time as relief is given through an increase in the duty of beaded 
bags. 

May 23, 1934 

Code Authority Ladies' Handbag Industry: 

The undersigned, importers of beaded bags, have carefullv studied the 
contents of the proposed petitior to b e submitted bv von on behalf of the beaded 
bag manufacturers to the President of the United States, under the provisions of 
the Nat onal Industrial Recovery Administration, Title I, Section 3e, and find 
statements contained therein with respect to the conditions of the industry in 
the United States; the conditions stated as existent abroad; to the conditions 
surrounding the importation of beaded bags, which are materially erroneous, and 
the true facts do ot justify an application to the President of the United 
States or the granting of such application by the President of the United States. 

9811 



-330- 



We reauest that as, a member oi the Code of Fair Competition, by which this 
application is presented, that we be advised of all conferences, hearings, or 
other steps taken with any officials relative thereto. 

. • •... .. - Respectfully, •• • 

Gold -Seal Importers, Inc. 
(signed) J. J-. Newman, Pr°s. 

Max Tannenbaum Co. 
(signed) Ma- Tannenbaum 

Harry Roth 
(signed) .Harry Roth 

Marvel Bag Co. 
(signed) Adolph Schecter 



REPORT RECEIVED PROM KAPLAN f: GORDON- CORP. 

... -May 11, 1934- 

Code Authority Ladies' Handbag Industry • 

303 Fifth Avenue 

New York City ■ • • 

Gentlemen: 

I wish to call y^ur attention to a resolution passed upon by the members 
of the beaded bag division which no doubt will be offered for vour consideration 
and approval, and I would like to make the following corrections. 

The resolution as it no 1 - stands may be interpreted that articles given 
out to homeworkers rjrior to submitting such articles to the impartial loerson ( 
or party shall constitute non-comr>liance of the code. This would constitute* 
a challenge to the honesty, and ability of the manufacturers in our beaded bag 
division and I must, therefore, most urgently protest against such unwarranted 
slur on our members, however unintentional. 

I therefore urge you to include in this resolution a statement that all 
items shall be submitted to the impartial -oerson or party for approval and may 
be submitted either'- before or after the work hs-s been- given out to the home- 
workers. This statement would permit the impartial person or agency to operate 
more efficiently for the benefit of the . entire- industry as otherwise it will 
without a doubt, at the" height of ' f he season, .paralyze our industry on account 
of ^he impossibility to pass upon all samples- which will be submitted for 
ap-sr^val, within a short time. 

I am certain that no human being, no matter. how experienced he may be in 
our industry, can estimate the time required to manufacture a beaded bag without 
actually timing the making of it, unless such estimate of time be entirely 
arbitrary and discriminating in many instances. 

9811 



-331- 



At least 4000 hours, I believe, would be required to determine the time 
necessary to manufacture the articles which would be submitted to the im- 
partial person or agency. These 4000 hours o^ wor v will have to be performed 
within one month, therefor = requiring the employment of 25 persons at the 
rate of a forty nour <-'eek. 

25 crochet headers would reauire a verv lar^e space and cannot be had 
without taking these workers away, from their active work. Neither are these 
25 crochet headers available as inside ^or'-ers ?s this industry is primarily a 
homewor 1 " industry. 

I also want to call to your at f ention that the resolution should include 
the statement that the impartial person or agency which is to be designated 
by the Code Authority shall be with the approval of the members of the beaded 
bag division , as only such person who would receive this approval could ef- 
ficients carry out the work required. 

Regarding the increase in tariff, I wish to offer for your approval the 
following suggestion: namely, that we petition the government to increase 
the duty to the maximum permitted by law only on articles completely finished, 
and to maintain the present duty on articles unfinished and to lower the duty 
on loose or strung beads. , • 

This would positively be to the best interest of our entire industry, 
particularly to" the workers, as the increase in duty on finished articles 
would force the manufacturers to finish *he articles in the United Sta.tes, 
thereby creating work for handsewers ,r, hich are easily availahle and of which 
there are many unemployed. It would also prevent department stores from 
purchasing completely finished articles abroad, thereby keeping so many 
American workers out of work, and would force the importers to establish 
finishing departments which would engage additional workers. 

The maintenance of the present rate of duty on unfinished articles would 
be a distinct benefit to our industry due to the fact that the amount of 
crochet- headers available in this country are entirely too few to be able to 
make the amount of bags required. The industry could employ all the workers 
available on better priced bags, particularly with the granting o"f the 25ii 
per hour r,ate for homework and. if and when the government should lower the rate 
on beads and Japanese imitation pearls. 

The requested increase in duty as it now appears in the resolution is 
positively-useless and of no benefit to our industry. On the contrary, it 
would be detrimental. First, the increase in entirely too little to benefit 
the industry and second, should the increase be much higher on all articles, 
finished and unfinished, it would ruin the industry on account of the high 
price of the articles as- consumers ultimately would find other items to buy 
at lower prices.' 

The suggestions I have offered would benefit the workers, business men, 
and the consumers, therefore the entire industry. 



9811 



-;- ,a~ 



As a member of the committee on homPwnr v , I wish to thank Mr. Mittenthal 
for the interest he has shovni us by drawing up the resolution end I ?m rare 
that it nas not his intention to include or exclude anything which may be of 
detriment to our industry. 

Again, nay I urge you to give very careful consideration to my suggestions, 
I would be very glcd to apoear before you to /give- you additional data, if you 
so desire. I am certain it would be ^o tha Interest ->f the industry. 

Respectfully yours, 
(signed) J* Kaplan 

Kaplan & Gordon Corp, 



Meeting of the Beaded Bag Importers held in the office of the Code Authority, 
May 15, at 11; 00 A, M, , ' " . ; 

Present: \ ■'" ' .'■ 

Mr. S. Steinhart . • . ■■ ■, • .,'.'■' 

.Mr. H,.,Roth 

Mr, Jr is ?wc?an . •'..'■".• 

.Mr. Tai n ;ubaum ' . 

Mr. A. Schenker '''•.' 

The request for this meeting was for the purnose 'vf refuting statements 
made in the petition passed by the Beaded Bag Manufacturers at their meeting 
on May 7, 

They asked to have the following statements corrected stating that there 
are not 25 manufacturers of beaded bags, but at- the very most 15, the other 
10 are importers. 

They also state that the 5000 worker? should not be more than 1000, 
claiming that there is a large duplication of the same workers who work for 
more than one manufacturer. 

They also claim that the duty is not always 60$, that a great many bags 
come in at 90$. A statement was made that 70$ of the imports from France pay 
90$ duty. ■ 

The committee questioned the accuracy of the statement that 5^ an hour 
is paid to workers on beaded bags in foreign countries. Also to the policy of 
figuring 10$ exoense in bringing in beaded bags. They claim that it never costs 
less than 20$ 

The committee claims that imports that were brought in last year at a cost 
of $1,20 each, laid down, now cost K 2 4 97. Also that the importation of beaded 
bags has declined 50$ within the past year. 



9811 



-ooo- 



A request was made that we obtain informatior from Mr, Homeyer of the 
Customs House regarding the average rate of duty and the oercen f a£-e of decline 
on inroorts of beaded bags. 

The committee promised to submit their brief in suDr>ort of their on- 
position to the petition of the Beaded Bag Manufacturers, 



May 19, 1934 

Mr. A. Mittenthal 

Code Director 

Ladies' Handbag Industry 

New York, N. Y. 

Dear Sir; 

Replying to your letter of May 14th, beg to sav I distributed for A. I, 
Magid Co., 14 E. 33rd St. N. Y. City and the Inroort Bag * Bead CoriD,, 25 W. 
35th St, ¥, Y. City, but have received no work since the Ladies' Handbag Code 
became effective.., ~ . 

Prior to the Code, I received from pbout $3 to $6 oer dozen for seed and 
wooden bags and my gross orofit ranged from about 60, t to $1 oer dozen, 

I do not know the average wage my headers earned oer hour because I do 
not know how long it takes to make a bag. 

It is hard to sav how many hours a header works in a home, A married 
woman might only bead two hours a day whereas a single e;irl might work six, 

I never had any wor v done by children. 

In my opinion it would be a great hardship to headers if homework were 
lorohibited entirely. 

I do not have any suggestion to make as to a better method for handling 
homework that would give the homeworkers the wage they are entitled to receive 
under the Code, 

Thanks for taking this matter uo with me by mail. 

Yours very truly, 



9811 



-334- 



Dear Sir: 



I take -pleasure in giving, you my analysis of the home tag industry 

My opinion and information is' "based on 3 years experience as a contractor and 
design originator. 

The contractor gives a money guarantee corresponding to the value of the 

is beads, and sometimes the thread and 



material he take 



away 



He receive. 



delivers the finished hags at the factory* Hs -pays his transportation both 
ways, besides the time required to go and come back from the factory. ' 

The contractor distributes th Q beads and thread from his -place to the 
homeworkers, and many times has to t^ach them how to make new models. He re- 
ceives the finished bags, inspects them and brings them to the factory, where 
he does not receive always the payment for the bags delivered, rin soite of 
the fact that he -pays the homeworker upon receipt of the finished bags. The 
eontractor assumes all the riste in che distribution of the material to the 
homeworkors and many timed must visit the. home of the workers ,to obtain the 
return of the bags and sometimes,; if. he does not use good judgment in giving 
the material to the home^r ,-ker he :ls called upon to, -pay. for the material 
not returned^ at ft ctory fancy 02 i.ceso 

Below is a statement shoving a study of labor cost of bagG, per doz.: 



TYPE 


QUANTITY 


AVERAGE 


PAID TO 


PAID 


BY FACTORY 


CONSUMER 




CF 


■OF BEADS 


TIME (each) 


HOMEWCMEH : 


TO CONTRACTOR 


PRICES 




BAG 




• 
















Zi-p-oer 


800- 


1 hour 


@4 rf 






12* 


$1, 
1. 


,00 
,00 




Envelope 


950 


12 hour3- 


10 A 




Zipper 


1350- 


2k hours 


23 1/3* : 


28 


to 30<* 


. 1, 


,95 




Envelope 


1550 


3 hours 


2ojt 




28 


to 30,* 


1, 


,95 




Zioper 


• 1850 


from 3to4 hrs.' 


' 29d 






39<j! 


'2, 


,95 


( 


Env lope 


2000 


from 3to4J? hrs. 


30 to 


32a* 




40^ 


2. 


.95 




Ziooer 


2300 


from 5to6 hrz. 


40 to 


45^ 


50 


to 55rf 


4, 


,95 




Envelope 


2600 


from 6to7 hrs. 


45 to 


50a! 


55 


to 60^ 


4, 


,95 





I do not give you the cost of the beads, although I understand that the 
average landed cost in UrScAo for white beads (1000 beads) is from 24 to 26 
cents, and colors from 18 to 22 cents, 

The two best seller? are the $1„00 line and $1.95 bags. 



The code establishes 35rf oer hour for this type of work. To enforce this 
wage means that the ^rice to be -paid to the worker, would have to be increased 
about four times, and the dollar line would have to be sold $1.50 to the 
consumer and $1.95 line would have to be sold about $2,50. Will the consumer 
buy at that orice? 

9811 



-335- 

We cannot legislate supply and demand. We cannot create demand by law. 
We cauno' legislate on wages when people need to obtain work even at low 
wages. While distributing work, I have often given beads to men who were 
of the so-called "white collar" class. I am myself in this starving con- 
tractor business because I cannot pet a decent job, and I em quite happy 
in it, a.s it gives me the opportunity to earn something for mv family. 

The manufacturer faces two dilemmas: to close his factory or trick the 
law, if the law means higher wages, which makes the merchandise cost higher 
and thus becomes not saleable. The worker is quite willing to be victimized 
by the manufacturer and sign any receipt for high wages which he did not 
receive, -orovided he gets something which will give him bread, shelter and 
some clothing -for his family. A quarter loaf of bread is better than none 
regardless of wages established by la.w. 

A homeworker, who with the assistance of other members of his family 
can average 6 hours a day's work, would be satisfied to earn 20 cents per 
hour or $1.20 per day. 20 cents an hour would make possible for the bag 
industry to live. 

It is well known to you that the homeworkers 1 wages in "Europe, Asia, 
Latin America, etc. are as low as the equivalent of ^rom one to two cents 
per hour and naturally bags can be imported from Czechoslovakia in spite of 
the high tariff, if the manufacturer here pays 35itJ per hour, provided, of 
course, that the consumer will buy bags if instead of beinp- sold at $1.00 are 
sold at $1.50*. The increase of imports from Japan in spite of our low dollar 
and high tariff, demonstrated that we are vulnerable as soon as wages enter 
into a cost, and the same thing will apply with "Europe in regard to bags. 

I honestly believe that wages of 20 to 25^ per hour would be fair and 
would not kill the bag industry. 

Yours truly, 



I am a homeworker on beaded bags working for one of the largest firms 
in the industry. At your request I have called to give you the information 
asked for on beaded homework. 

My wife and self just finished 48 dozen of beaded bags. We worked 12-? 
hours a day each from the hours of 7:00 A. M. to 10:00 F. M. , only taking 
out time for meals. We finished these 48 dozen bags in one week, working a total 
of 75 hours each during the week, and we earned $22 for the comiolete job, or 
$11 each. We consider ourselves fast workers. 

We are paid 4<f a piece to sew around a complete beaded bag, insert and 
sew in linings, and sew on the button fasteners. 



9811 



....... . -336- ...... . . ... 

Fay 18, 1934 

REGARDING T: 'E USE OF N.B.A. LABELS II! B SiiDED 
HA1EBAGS PARTLY IMFOR T ED MP FINISHED ,1?: TilE 
.'. • UNITED STATES . 

Gentlemen: 

In order that an official decision may "be had from the Administration 
regarding our right to issue such_labels, we have filed the required protest 
to obta.in such official ruling. In the meantime, the Code Authority will 
issue labels to headed hag manufacturers for hags -partly imported and finished 
in the United States,. 

Very truly yours, 



Code Director 
Ladies' Handbag Industry 



May 19, 1934 

Mr. A. Mittenthal 

Code Authority- Ladies' Handbag Industry 

303 Fifth Avenue 

New York, N. Y. 

Dear Sir: 

We are in receipt of a letter dated May 18th whereby it is stated that , 
the Code Authority will issue labels to beaded bag manufacturers for bags 
uartly imported and finished in the United States. 

We believe this is an injustice to the American manufacturers of beaded 
bags. You ask us to pay a living wage' to American workers. You ask us to 
limit our hours of work. In all fairness to the American workers, we believe 
that the N. B. A. labels should only be sewed in b.egs thP.t are made in America. 

There are a few importers of beaded bags who through subterfuge are 
trying to have labels sewed, in beaded bags that are • inroorted. from Europe, but 
on a pretext that they are sewing the linings in the bags in this country. The 
beaded bag plate that is imported from Europe is really the whole article. The 
linings are only a small fraction of the labor or construction of the bag. We 
do not believe that any fair minded authority will nermit labels to be sewed in 
beaded bags or any other article that is inroorted from the other side. We 
earnestly ask you to give this matter your nronrot attention. 

Thanking you, we are, 

Very truly yours, 

9811 



May 19, 1934 

Mr. Pearson 
45 Broadway 
New* Yor'- City 

Dear Sir: 

Unclosed release find a conv of a notice received this morning from the 
Code Authority, nertaininir to NRA labels to he sewed into headed bags, the 
makings of which are partly inroorted and nartly finished in this country. 

Havine; snent a life time in the headed has; business, both as an inroorter 
and as a manufacturer, I cannot see the justice in a ruling of this kind, 
since the inroort nart of a bag is 8$ whereas the finished -cart that has to 
be done in this country is not more than 2"£. 

You can therefore readily see that to continue under the ruling of the 
Code Authority and still maintain the meaning that the ERA stands for, would 
be an absolute imno c sibility. 

May I suggest to you before you allow this ruling to go into effect that 
you will give the domestic bead bag manufacturers a hearing. 

Trusting to hear from you, we remain, 

' .. Very truly yours, 



: - May 19, 1934 

Mr. Mittenthal 

Code Authority Ladies' Handbaar Imhigtry 
303 Fifth Avenue . ' 

New York City 

Dear Mr. Mittenthal: 

We have a, letter from you dated May 18th regarding the NRA labels being 
■out- into bags that are 3/4 manufactured in Europe. ' ) 

We must ask for your immediate assistance in checking this action as labor 
is naid at the rate of from 2S to 5d an hour in Darts of Eurone such as Belgium, 
Czechoslovakia and France. 

If labels are nerroitted to be nut into bags that are 3/4 manufactured in 
Furone under the lowest rate of wages, we as American manufacturers protest 

against such a ruling as the code demands that we nay 35-4 an hour as it 

will be impossible for us to comnete with foreign merchandise and will thus be 
com-oelled to nut out of work thousands of American women now em-cloyed in the 
beaded bag industry. 



9811 



-338- 

We sincerely hcoe you will tpVe immediate ste-os to orohibit FRA labels 
being -out into bags that are not wholly manufactured in the United States* 

It is imperative that you act on this at once, before the NRA labels are 
allowed to be -out into the bags. 

V?ry truly yours, 



Dr. Earl Dean Howard 
De-out"'' Administrator 
Commerce Building 
Washington, D. C. 

Dear Dr. Howard: 



May 22, 1934 



The Beaded Bag Grouo of the Ladies' Handbag Industry has asked for an { 
official ruling as to whether beaded. bags partly imported and finished in the 
United States will be -oermitted to use an N. R. A, label issued by the Code 
Authority of the Industry. 

The Beaded Bag Industry is evenly divided on the question. Those who 
inroort bead covers and finish them into bags in the United States contend they 
should be permitted to have the label. Those who make the coraolete bag in 
the United States contend they should not be allowed to us^ the N. R. A. label. 
The Code Authority has ruled: 

"In order that an official decision may be had from the Administration 
regarding our right to issue such labels, we have filed the required protest 
to obtain such official ruling. In the meantime the Code Authority will issue 
labels to beaded bag manufacturer? for bags -oartly imported and finished in 
the United States". 

In order that we may obtain an official ruling I am enclosing three | 
protests filed by members of the Beaded Bag Grouo against the decision of the 
Code Authority ruling. The Beaded Bag Group is desirous of obtaining at the 
earliest oossible date an official ruling to guide them when olacing their 
requirements for early fall delivery. 

Very truly yours, 

Code Director 
Ladies' Handbag Industry 



9811 



May 18, 1974 



Gentlemen; 

There has "been an attempt on the part of the Code Directors of the 
Pleatine;,. Stitching and Bornaz and Hand "Embroidery Industry ti include "beading 
on ladies' handbags in "heir Code. < 

W-> have just succeeded in obtaining a stay, to prevent this Code from 
interfering with the makers of headed ba^s. This action we deemed necessary 
in vi'w of the fact that the Code of the Pleating, Stitching and Bonnaz and 
Hand "Embroidery Industry abolishes all homework after June 1, and which would 
by its o-oeration stop such homework by the manufacturers of beaded bags. 

Very truly yours, 



Code Director 
Ladies' Handbag: Industry 



The Beaded Bag Industry is a division of the Ladies' Handbag Industry. 
There are about 20 manufacturers; 14 can be classed as manufacturers of beaded 
bags and 6 as" importers. However, in both classes there is an overlapping, 
some manufacturers also do importing and importers w.io do some manufacturing, 
and others who make all of their product in the United States. 

Bea.ded bags are imported either as a complete ba^ or as beaded covers and 
finished into a bag in the' United States* The chief countries from which these 
bags are imoorted are Belgium, France, Czechoslovakia and Ja-oan. The present 
tariff on beaded bags is from 60$ to 90$, depending on how the beading is 
appi ied. The cheat) bags mostly come in at 60$ duty. .A g-reat many imported 
from Prance come in at 90$ duty. The total number- of finished bags imoorted 
in 1933 were approximately 52,053, There are no accurate figures obtainable 
for the number of beaded bag covers 'imported, or 'the' quantity of beaded bags 
imoorted during the first four months of 1934, The total volume of sales for 
the industry for the year 1932 were about- $3,-000,000. 

With this analysis of the industry it must be apparent that there is a 
decided conflict of interests amongst the groups of manufacturers who make a 
complete bag in the United States, those who import the covers and finish the 
bags in the United States, and those who import the finished bag. It is the 
contention of the group who make the complete bags in the United States that 
the duty on the imported "bagrs should be raised the full 50$ allowable under 
the National Recovery Act, and also that no N< R, A. -.labels should be issued 
by the Code Authority for use in bags partly imported and finished in the 
United States. ' It is the Contention of the group who import the beaded covers 
and other parts and finish the bag in the United States that they should be 
allowed to use the N. R, A, label since the work in finishing the bag is 
performed by American labor. This group does not protest against any proposed 
increase in duties. It is the contention of the importers of beaded bags that 
the present tariff f u 1 ly protects the American manufacturer of beaded bags and 
no increase in tariff is required, 

9811 



-340- 

At a meeting of the committee aouointed "by the Chairman of the Code 
Authority to study homework it was decided to call a meeting of all known 
members of the Beaded Bag Industry for the purpose of presenting a resolution 
requesting the Code Authority to petition the Tariff Industries Board of the 
N. R. A. to increase the tariff on headed hags the full 50$ provided for by the 
National Recovery Act, also to petition the Code Authority- to allow homework 
on beaded bags at the rate of 25i an hour instead of 35r* an hour as provided 
for by the Code. The manufacturers held a meeting at the Hotel McAlpin on 
May 7. There were 14 firms represented at the meeting. The report of the 
committee was read and explained. A resolution was made and seconded that 
the report of the committee be adopted. The result of the vote was 7 for. 
the' resolution, 4 against, 3 not voting. 

From the statements furnished by manufacturers, contractors and workers 
it is evident that there is no compliance on the 35rf an hour rate. The 
evidence of workers shows conclusively that the homeworkers have no part in 
fixing the piece work prices, they have no bargaining cower and generally 
take what price is offered them-. It is the custom of the beaded bag industry 
to engage homeworkers either individually or through contractors. When the 
work is given to the individual homeworker a small security is demanded by 
the manufacturer, usually not more than a few dollars, a sum not sufficient 
to cover the value of the materials entrusted to- the homeworkers, but more for tr 
purpose of establishing responsibility. When wo r v is givsn through contractors, 
'the contractor is made responsible for all mat3rials and the deposit is 
usually more substantial.' The contractor gives out -the wor v to the . individual 
homeworkers,' he assumes all responsibility, collects' and delivers the. bags to 
the manufacturer, furnishes the cotton to the worker, and in return cays the 
workers himself; for this service the Contractor usually retains about 20^ 
of the price he receives. From the evidence furnished by the contractors and 
homeworkers the average wage earned t>y the homeworker is from 1& to lOaJ an 
hour. There is absolutely no method of determining the number of hour worked 
by a homeworker. From* the statements of these workers from 10 to ,12 hours a 
day is the average. 



( 



The homeworkers are deeply concerned about the abolition of homework 
claiming that it will deprive them of their means of earning at least a 
portion of their livelihood. < The contractors are in favor of abolishing 
homework, claiming that it will give ^hera an oiDportunitv to open contract 
shoes and bring the homeworker into their shops. The manufacturer does not 
wish to. have homework abolished since he cannot assume the overhead required 
to establish and maintain the number of .workers tha.t he would require to 
produce the volume of .his product in his own factory. 

The situation is more complicated by the contention of the Code Authority 
of the Pleating, Stitching and Bonnaz and Hand Embroidery Industry who claim 
that crochet beading is part of their Code and that the Code of their industry 
abolishes all homework after June 1, 1934. A stay has been, obtained from the 
provisions of this Code for the beaded bag manufacturers on' the ground that 
they sell only the finished product and that the product is definitely a hand- 
bag, that the crochet beading is only incidental. 

Labels for Partly imported bags, it has' been ruled 'that labels will be 
furnished for use in such bags pending a final decision from the Administration. 

9811 



4 -.341- 

A protest necessary to obtain such an official ruling has already been filed 
with the Administration in Washington. 

The matter of wa^e rates, it is evident that if *"he American manu- 
facturers are compelled to -nay Z5i an hour + 'or homework, they cannot hope to 
compete with the imported bags. If they are permitted to have a rate of 25^ 
an hour for homework, they can -produce some goods comparable with imports. 
The manufacturers of beaded hags are willing to maintain a machinery for 
compliance with the 25^ an hour rate, if and when granted. 

As a result of an impartial investigation of the Beaded Bag Industry by 
the Code Director, it is advisable that the exception asked for, making a 
minimum rate of 25^ an hour for homeworkers, be granted to the Beaded Bag 
Industry, but only so long as they maintain and comply fully with the rules 
and regulations to be established by them for the fixing- of piece work prices 
to be paid to homeworkers on beaded bags. 



A. Mittenthal 

Code Director 



9811 



-342- 



EXHISII P 

Sta.ndard Cost Formula 
Part I - Code Authority Presentation 
Part II - Coniraent, Research and Planning 

Division 



( 



9811 



-343- 



EXHIBIT P 

KAhD 3AC-S 

STANDARD COST FORMULA 

Acknowledged by Mr. Boyd but never approved as no such wore ap- 
proved. Never laid before Industry, therefore never taken advantage 
of. At the present time September 23, 1935, preparing a calculation 
which it is hoped will be effective. 

To arrive at the cost of the product manufactured: 

1. Figure the cost of all Direct Material and Direct Labor. 

2. To the total of Direct Material and Direct Labor Costs add a 

percentage of overhead representing all other costs (which 
must include Factory Expenses, Designing. Expenses, Selling 
Expenses, Distribution Expenses, Administrative and General 
Expenses. ) 

Illustration of the above method (all figures are assumed): 

1. Cost of Material $3.25 
Cost of Direct Labor 3.00 

Total Direct Costs $5.25 

2. All Overhead Costs - (33 l/3> of Direct 

Costs ($5.25) 1.75 

Total Cost $7.00 

The resulting figure ($7.00) represents the cost of the product 
manufactured, and to sell it for less than this amount would be in 
violation of the Code. The 33 l/3$ in this example is merely an 
illustration. 

Determination of Overhead Percentages: 

The Overhead Percentage to be used must be computed by each in- 
dividual concern in accordance with the plan described on pages 2 to 
10. However, no percentage shall be used less than 33 l/3,b. Ex- 
ception shall be ma.de to this rule by the Code Authority if the 
member of the Industry requesting such exception is prepared, on 
demand, to submit to an agency of the Code Authority subject to audit, 
a budget and basis therefor which will warrant a lower overhead figure. 
Also in special circumstances or for particular occasions where strict 
adherence to the rule would work excessive hardship, similar exception 
shall be made by the Code Authority upon showing of justification 
therefor, provided, however, that any member of the industry whose re- 
quest for an exception to this provision is not granted by the Code 
Authority shall have the right of appeal to the 1IEA. 



9811 



-344- 

THE PURPOSE OP THE CODE OP PAIR COMPETITION IS TO PROVIDE AGAINST 
UNFAIR TRADE PRACTICES, CREATED BY UNSCRUPULOUS MEANS, AND TO PREVENT 
SUCH UNFAIR TRADE PRACTICES, A MINIMUM OVERHEAD PERCENTAGE IS ES- 
TABLISHED. THIS FIGURE DOES NOT PERMIT MANUFACTURERS WHOSE PERCENTAGE 
OF OVERHEAD IS GREATER THAN THE PERCENTAGE MENTIONED TO FIGURE ANY LESS 
THAN THEIR ACTUAL PERCENTAGE. TO PREVENT HARDSHIP IN PARTICULAR SITUA- 
TIONS CERTAIN EXCEPTIONS HAVE BEEN AUTHORIZED. 

To arrive at the correct overhead to "be added to the total cost of 
Direct Material and Direct Labor, it is necessary to prepare a budget 
for a period of a year's operation. The estimates of figures entering 
into the budget must be made from records of former years' operations 
and experience, and should be based upon ai expectation of normal 
business conditions. 

ILLUSTRATION OP A BUDGET 

(1) Estimated Net Sales $100,000 

(2) Estimated Discounts Allowed to Customers 3,000 



$ 97,000 

(3) Estimated Direct Material and Direct 

Labor $66,000 

(4) Estimated Overhead Expenses 22,000 

TOTAL COST 88,000 

(£) Profit $ 9,000 

(6) In the above illustration the estimated overhead ($22,000) 

is 33 l/3p* of the esti'oated Direct Material and Direct Labor 
($66,000). Therefore 33 l/3p is the lercentage to be used 
in the Cost Formula to figure the cost of each style of bag. 

The percentage of overhead must be computed by ea.ch individual 
concern, and each one will use his percentage figure arrived at in this 
manner (except as provided on Page 1.) No flat percentage rate of 
overhead for the entire industry can be used. 

TO PREPARE THE BUDGET 

(1) Estimate the probable Net Sales. (Gross Sales, less 

Return Sales, Less Allowance) 

(2) 3ased on the estimated Net So.les, figure the Discounts 

Allowed to Customers. 

(3) Based on the estimated Net Sales, figure the necessary 

Direct Material and Direct Labor Costs to produce the 
amount of product sold. 

(4) Based on the estimated Net Sales, estimate the total of 

all other costs, factory Expenses, Designing Expenses, 
Selling Expenses, Distribution Expenses, Administrative 
and General Expenses (hereafter referred to as "Overhead 
Expenses") necessary to produce and sell this amount of 
product. 
9811 



-345- .. 

(5) Estimate the amount of profit that will be rnade on this 

volume of business. 

(6) To arrive at the Percentage of Overhead to be used vrtien 

figuring the Cost of each style of bag, determine the 
percentage that the total Overhead Expenses is of the 
combined total of Direct Material and Direct Labor cost. 

All estimates malcin 6 up the budget should be reasonable. 

The estimate of probable net sales for the year should represent 
an amount thet the concern can reasonably be expected to sell during 
the budgeted year. 

The estimates of Direct Material, Direct Labor, and Overhead 
Expenses should represent amounts that the concern must reasonably ex- 
pect to expend for these items during the bedgeted year based on the 
records of former years' operations and experience, with due regard to 
changes that may be expected to occur during the budgeted year, and 
with the exceptions noted horeafter on ne.^e 11. 

Fixed costs relating to buildings, machinery and equipment, such 
as rent, depreciation, insurance and taxes, and fixed salary items 
must be put into costs on a basis of normal rates of operation. 

Do not overlook the method of handling interest and other items 
described on page 11. 

The Standard Cost Formula sets forth rigid provisions, but minor 
deviations that would not materially change the method or results may 
be made. 

DIRECT MATERIALS 

Direct Materials are to include all those materials which can be 
traced directly into the product. 

Price all Direct Materials for cost formula at market price pre- 
vailing at any time within thirty (30) days prior to date of sale or 
at actual cost if purchased within four (4) months of date of sale, 
whichever is lower. 

Exception to this rule may be taken only upon application to, and 
approval by, the Code Authority. 

Incoming Freight and incoming cartage on raw material are re- 
garded as a part of the Direct Material Cost. 

The following items are classed as Direct Materials: 

Cover (leather or fabric) Cotton and pins, etc. 

Lining Frame 

Pocket lining Purse Frame 

Rubber cloth Zipper 

Y/adding Mirror 

Flannel Fittings 

Packing material Ornaments 

Paper Buttons 
9811 



Cement 
Welding 

DIRECT LABOR 



-346- 

'Boxes 
Tissue' 
Labels 



Direct Labor is to include wages paid for labor performed spe- 
cifically on and charged directly to the product. Any other labor is 
indirect labor and must be included in the Overhead Expenses. 

In estimating the cost of Direct Labor operations, there must'be 
included the difference paid when the earnings of piece workers fall 
below the minimum wage. 

All Direct Labor must be identified and separated from that part of 
the payroll that is classed as indirect and other overhead labor. 

The following includes all the items of Direct Labor generally 
applicable to the Handbag Industry. Any special or unusual direct 
labor operations, or direct' labor performed outside the factory such 
as embossing, stripping, etc., should be added. 



CUTTING 

Cutting by Hand 
Cutting by Clicker 
Cutting Rubber Cloth 
Cutting Lining 

PARI NO 
Paring 
Burnishing 
Splitting 

EMBOSSING 



Cutting Wadding 
Cutting Interlining 
Cutting Papers 



SEWING 

Sewing Handle Trimming Cottons from Linings 

Sewing Handle on Cover Trimming Cotton from Handle 

Sewing Covers on Bottoms Sewing on Welding 

Sewing Misror Pockets on Linings Cutting apart 3ottoms from Welding 

Sewing Frame Pockets Latching Covers, Bottom and Handles 

Harrowing Frame Pockets Hanging on Wadding on Linings 

Sewing together lining Sewing together Lining and Covers 

Sewing on Zipper 

MAKING LIEBTC-S 

Hanging on Paper on Silk for Pocket Bending Pocket 

Cementing Silk on Paper Hanging on Muslin on Silk 

Turning in Pocket Marking Silk for Pockets 



POCKET BOOK WORK 
Stripping on Covers 
Hanging paper on Cover 
Cementing paper and Cover 



Hanging Paper on Silk 
Cementing Silk 
Turning Silk 



9811 



Puttin 6 in Button 
Putting on Ornaments 
Putting on Handle 

Making tucks or pullers 
Turning in Cover 



-347- 

Setting together Silk and Cover 
Marking Covers for Sewing on Handle 
Putting paper on back of bag for 

handl e 
Trimming Edges of Covers and Bottoms 



DIRECT LABOR 

HMD LACING 

TURNING 

Turning Bag, Shaping and Hammering 

Turning Frame Pockets 

FRAMING 
Framing Purse 
Framing Pockets 
Framing Beg 

FRAME COVERING 
Covering Frame 
Covering Pockets 
Covering Purse 

EXAMINING AND PACKING 
Trimming Thread and Examining 
Wrapping in Tissue 
Put tin,., in Boxes and Labeling 

OVERHEAD EXPENSES 



Overhead expnnses include all expenses which cannot be treated 
directly into the product. They do not include Direct Material and 
Direct Labor. 

The following is a detailed list of Overhead Expenses classified 
as to Factory, Designing, Selling, Distribution, and Administrative 
and General. This list covers all of the items of Overhead Expenses 
generally applicable to the Handbag Industry. 

Fixed Costs relating to buildings, machinery, and equipment, such 
as Rent, Taxes, Depreciation and Insurance, should be included only for 
such buildings, machinery, and equipment actually used to manufacture 
the product sold. Expense of maintaining and protecting buildings 
completely closed and equipment completely inoperative is to be ex- 
cluded from Overhead Expenses entering into the Cost Formula. 

Salaries of Executives should be included in Overhead Expenses 
for the purpose of the Cost Formula only to the extent of a reasonable 
amount, taking into consideration the size and nature of the business 
and the proportion of such salaries of owners and chief executives. 

Expenses not to be included in Overhead Expense for the purpose 
of the Cost Formula are listed on page 11. 

9811 



-348- 

A. FACTORY OVER HEAD - 

Executive Salaries (Production) 

Supervision (Foreman) 

Indirect Labor 

Floor Boys Salaries 

Bag Repair Man 

Factory Office Salaries 

Buyers Salaries 

Receiving Salaries (Direct Materials) 

Stockroom Salaries (Direct Materials) 

Foreign Buying Expense (For Direct Materials) 

Factory Supplies (Oil, Belting, Paring Knives, Needles, Emery 

Wheels, etc.) 
Dies, Small Tools, and Parts 
Machine Repairs 
Machine Rentals 
Royalties 
Depreciation of Machinery and Equipment (Except on completely 

idle machinery and equipment) 
Depreciation of Factory Building (Except on completely idle 

buildings) 
Amortization of Leasehold Improvements (Except on completely idle 

improved property) 
Porters and Cleaners 
Light - Fa.ctory 
Heat 
Power 
Wat er 

Factory Trucking 
Rent - Factory 
Local Taxes 
Power House labor 

Insurance - Fire, Compensation, Misc. 
Protection - Electric, Payroll. 
Watchman Salaries 
Factory Traveling Expense 
Sundry Factory Expense 

B . COST OF REPAIRS TO BAGS 

Repairing, of bags has always been an item of considerable expense 
to the industry. The actual cost of labor and materials Consumed in 
repairing Dags together with handling and forwarding charges (two ways) 
is rarely if ever, included in the original costs, nevertheless, in 
some cases, this item amounts to as much as 2,'o of the sales. It is 
important that this item of expense be figured in the cost of the 
bags as an overhead expense. 

The following items go to make up the cost of repairs: 

Cost of Direct Materials used for repairs $xx 

Cost of Direct LaDor in making repairs xx 

Handling of repairs - clerks, wrapping 

correspondence, etc. xx 

Forwarding charges from and to customer xx 

Total Cost of Repairs $xx 
9811 ~ =*== 



-349- 

C. LOSS (MARKDOWNS) ON INVENTORY 

It is not unusual for a handbag manufacturer having a volume of 
sales of $500,000 during the yer.r to find at the end of the year an 
inventory on hand amountin to $25,000. 

This inventory will nrobably consist of some frames and ornaments 
which can be depreciated at least 50 per cent immediately and even 75 
per cent if they har:-) en to be i;n small quantities. 

The leather stock inventory is usually in fall colors, in uneven 
color assortments, which can be depreciated 50 per cent. 

Finished goods inventory on h-aid usually consists of the least 
desirable styles in broken color assortments which can be depreciated 
from 25 to 50 per cent. 

It is safe on the average, therefore, for any manufacturer of 
handbags to figure 50 per cent depreciation on his inventory at the 
end of the year. 

Unless this item of $12,500 loss in inventory is figured, into the 
original cost it is more than likely that what ' appeared, to be a 
profitable year may result in an unprofitable year when the loss in 
inventory is charged rgainst the "-rofits. For example: 
"» Inventory $25,000 

Less depreciation 50 -)er cent 12, 500 
Value of inventory on hand $12,500 

Total yearly sales $500,000 

Estimated Profit $10,000 

Loss on inventory 12. 500 

Deficit $ 2,500 
Percentage of loss on sales 3g$ 

This example may vary with different types of manufacturers making 
different kinds of bars. With some, the inventory may be higher and 
the percentage of markdowns low^r. For example, a manufacturer may 
have a $50,000 inventory with a markdown of only 25$, depending upon 
the kind and nature of the inventory. The principle involved, however, 
must be allied in every case. Each manufacturer should carefully 
study the conditions in his own particulrr line. 

D. DESIGN OVERHEAD 

Executive Salaries (Designing) 
Designers Salaries 
Sample Making Salaries 
Sample Ih.terials 
Raw Materials used in Designing- 
Purchases of Sample Bags 
Sundry Desi & ning Expense 



9811 



-550- 

E. SELLING OVERHEAD 
Executive Salaries (Selling) 
Commissions - Salesmen 
Salesmen's Salaries 

Loss on Salesmen's Advances 

Showroom Salaries 

Amortization of Leasehold Improvements - Selling 

Advertising ' 

Advertising Salaries 

Royal ties 

Auto 'Exnense 

Depreciation of Auto 

Rent - selling 

Light - selling 

Sundry Selling Expenses 

F. DISTRIBUTION OVERHEAD 
Shipping Salaries 

Stockroom Salaries (Finished Bags) 

Wrapping and P.- eking materials 

Freight, Express, Trucking, Parcel Post, Carfares - Outward (shipping 

Sundry Shipping Expense 

G. ADMINISTRATIVE AND GENERAL OVERHEAD 
Executive Salaries 

Office Salaries 

Insurance 

Stationery, Printing and Office Supplies 

Telephone and Telegraph 

Postage 

Auditing Fees 

Legal Fees 

Dues and Subscriptions 

Rent - Office 

Light - Office 

Electric Protection , 

Code Authority Assessments Expense 

Taxes - except Income Saxes 

Provision for Doubtful Accounts or Bad Debts Written Off 

Credit and Collection Expense 

Depreciation of Office Furniture and Fixtures 

Bank Charges 

Sundry General Expense 

ITEMS NOT ?0 BE INCLUDED IN OVERHEAD OR INCOME 

INTEREST ON BORROWED MONEY 

Interest on money borrowed should not be included in overhead 
costs, but for this purpose shall be considered as a non-operating 
expense due to lack of sufficient invested capital. 

LIFE INSURANCE - Owners, Chief Executives and Employees 

Premiums on policies insuring the lives of owners and chief 
executives, or on group life insurance for employees, must not be 
included in the overhead expenses but for this purpose should be con- 
sidered as a non-operating exnense. 
9811 



-351- 

FEDERAL, STATE, LOCAL INCOME TAXES AMD EXCESS PROFITS TAXES 

These must not be included in the overhead expenses but for this 
purpose shall be considered as r. non-operating expense. 

DEFERRED EXPENSE 

Expenses, such as insurance, paid for in the period under budget, 
but partly applicable to a future period, must be properly apportioned 
to the budget period. 

DONATIONS 

Donations of the character not allowed by the Bureau of Internal 
Revenue must not be included in overhead expenses. 

INTEREST ON INVESTMENT 

Interest on owner's investment or capital must not be included 
in the overhead expenses. 

INTEREST EARNED 

Interest Earned should not be included in operating income, but 
shall be considered as a non-operating income due to heaving sufficient 
capital invested to secure this income. 

NON-OPERATING INCOME AND EXPENSES 

Any unusual or extraordinary items of income and expense such as 
dividends, fire loss, special sales campaigns, development work, etc., 
must not be included in income or overhead expenses. Such items are 
classed as "Other Income" and "Deductions from Income" and are to be 
omitted in the Cost Formula. 



STANDARD CALCULATION SHEET 

It is mandatory that each manufacturer keep detailed records of 
the cost of each individual style of bag manufactured by him. 

For this purpose the Code Authority has approved a standard form 
of calculation sheet, a sample of which is shown on the following page. 

These Standard Calculation Sheets showing the detailed costs of 
each style must be available to the authorized agents of the Code 
Authority upon request. 



9811 



STANDARD CAL CULATION SHEET 
: =tJS2= ■ 



Code Authority 

L" dies' Er.ndbr.fi Industry 

SKETCH 



* 



Description 



MATERIALS 



Cover 

Lining 

. t . .». 

Pocket Lining 

Rubber Cloth .. 
■Warding 
Flannel 

Backing Materikl. 
P" per 
C ement 
Welting 

Cotton n.nd pins, etc. 
Frfine 

Purse Frame 
Zipper 
iiirror 
Eittings 

Ornaments 

Buttons ■ 

Boxes 

Tissue 

Labels 

Miscellaneous 



STYLE HO. 



TOTAL COST OF MATERIALS 



TOTAL COST 07 LA30R - Forwarded from reverse 

t , side 

TOTAL DIRECT COST 

Add: OVERHEAD EXPENSES (...^ of total Direct 

Cost) 



9811 



-353- 



Selling Price 

Less Discounts Allowed 

Net Selling Price 
PROFIT- 



TOTAL COST 

4. •• 



DIRECT LA30R COSTS 



GROUP 



CUTTING 



PARING 



EMBOSSING 



SEWING 



TURNING 



FRAMING 



FRAME COVERING 



MAKING LININGS 



POCKETS OOK WORK 



OPERATION 



Cutting "by hand 
Cutting by clicker 
Chopper 
Hand Grader 
Cutting Rubber Cloth 
Cutting lining 
Cutting Wadding 
Cutting Interlining 
Cutting -p.'iers 



Paring 

Burni shing 
Splitting 



Embossing 



S ew i ng nandl e 

Sewing handle on cover 

Sewing covers on bottoms 

Sewing Mirror Pockets on linings 

Sewing frame pockets 

Harrowing frame pockets 

Sewing lining together 

Sewing on Zipper 

[Primming cotton from linings 

Trimming cotton from handle 

Sewing on Welding 

Cutting anart bottoms from Welding 

Matching covers, bottom and handles 

Hanging on wadding 0:1 linings 

Sowin,.- together liniiy. an d cove rs 



Turning bag, shaping and hammering 

Turning frame "'ockets 



Framing nurses 
Framing pockets 

Framing bag 



Covering Frames 
Covering Pockets 
Covering Purse 



Hanging on paper on silk for pocket 

Cementing silk on paper 

Turning in pocket 

Bending pocket 

Hanging on muslin on silk 

Mrrking silk for -pockets __ 



Stripping on covers 
Hanging paper on cover 
Cementing paper on cover 



9811 



GROUP 



-354- 

OPERATION 



POCKET300K WORK- continued. 



Putting in buttons 
Putting on ornament 

Putting on handle 
Making tucks or pullers 
Turning in cover 

t Hanging paper on silk 

* Cementing silk 

___ Turning silk 

Setting together silk and cover 
Marking covers for sewing on handle 
Putting paper on back of bag for 
handle sewing 

Trimming edges of covers and bottoms 



HMD LaC I HC- 



Mand Lacing 



EXAMINING AMD PACKING 



Trimming thread r.nd examining, 
Wrapping in tissue, Putting in 
boxes r-nd labeling 



OUTSIDE LABOR 



TOTAL DIRECT LABOR 



FORWARDED TO PIRST PAGE - 
STANDARD CALCULATION SHEET 



9S11 



-355- 



February 1, 1935. 



MEMORAJ.IDUM 

TO: ' Mr. Leigh E. Ore, 
Leather Section, 
Assistant Deputy Administrator 

PROM: Or ton W. Boyd, 

Cost Accounting Unit, 
Research and Planning Division 

SUBJECT: Ladies' Handbag Industry.- Standard 

Cost Formula. 



This formula has been submitted under the provisions of Article VI, 
Section 8(i) and Article VIII, Section 14. . 

The first named section empowers the Code Authority to recommend 
the uniform cost and/or accounting system for each division of the 
industry which, unon ^pjpr.pviil "by the Administrator, shall become a 
part of the code. Any member of the industry is permitted to con- 
tinue the use of his current cost or accounting system provided that 
selling prices estimated by the use of that system shall not be less 
than the cost of the article determined, in accordance with the ap- 
proved formula. 

Article VIII, Section 14 prohibits sales below individual's cost 
as computed by the approved uniform cost system. Exceptions, however, 
are granted from th^t rule for the ">ur >ose of meeting competition , of 
another member who is not selling below his individual cost, and for 
seasonal clearance sales, distressed goods, etc. 

The approval or disapproval of this -iroposal is purely a matter 
of Administrative policy, inasmuch as if it were to be approved, it 
would effectuate the above cited sections of the Code of Pair Com- 
petition, each of which conflicts with PRA policies as set forth in 
the Office Manual. 

In any event,, this proposal is an unsatisfactory device for the 
effectuation of the no-selling-below-cost provision for reasons as 
follows: 

1. According to Page one, the minimum p.mount of overhead to be 
used in the determination of unit costs is 33-l/3$ of the direct costs 
(material, and direct labor). An exception to this rule will be per- 
mitted by the Code Authority if a member of the industry requesting 
the same is in position to demonstrate the fact that his actual over- 
head expense is a lower percentage of the direct costs. This pro- 
vision conflicts with Office Memorandum 238-3 which provides that no 
cost accounting system shall suggest differentials or percentages 

9811 



-356- 
which vould tend to "bring about arbitrary uniformity in costs. In 
other v/ords, each member of the industry should compute his own over- 
head on the basis of his own experience. 

2. The method of applying overhead to unit costs as a percentage 
of prime cost is obsolete and should not, therefore, appear in a cost 
recounting system to be a;r-iroved by the Adninistration. I would 
suggest that overhead be an lied in unit costs either as a percentage 
of the direct labor cost, or at a , iven rate per direct labor hour. 

I would personally prefer the use of the second alternative. 

3. According to page five, direct materials shall be charged 
into costs at the market price prevailing at any time within thirty 
days prior to the date of s-.le, or at actual, cost if purchased within 
four months of the date of sale, whichever is the lower. This pro- 
posal restricts the scope of the "cost or market, whichever is; lower" 
rule nrescribed by Office Mertorandum 26$. An individual manufacturer 

. should be permitted to»char : _e luLs Materials into production at actual 

cost, r egar dless of the date of the purchase of those materials. No 

doubt, the Code Authority in this propo sal wishes to prevent a manu- 
facturer from producing an old invoice and clrim that the materials 
billed thereon were actually employed in the manufacture of the bag 
in question. 

The following revision of the Code Authority's pronosal would 
brin^ it into harmony with Office Hcmorandum 265 and the same time take 
care of the situation which the Code Authority hcas in mind; "Price all 
direct materials for the cost formula at original cost or at the market 
price prevailing at date of sale, whichever is the lower. A member 
who claims that his ra.w materials were purchased four 'months or more 
prior to the date of the saLj must be nrcpared to prive his contention 
from his perpetual inventory or similar records. Otherwise, it is 
assumed that the first materials purchased were used in the manufacture 
of the earliest lots of bags." 

4. In order that there may be no confusion, the following state- 
ment should appear immediately below the caption "Items not to be in- 
cluded in overhead or income" on Page, II; "The expense items shown 
herein shall be excluded in the determination of the costs below which 
sales shall not be made." 

5. According to Pa_/e 9, the cost of repairs to b-^.gs shall be in- 
cluded in the factory overhead exiense. Many cost accountants would 
insist, with propriety, that the expense of repairing bags should be 
listed a,s a selling and administrative expense. The individual manu- 
facturer, should feel free to include tehe cost of repairing bags within 
that classification, ijith thejinderstandftig, of course, that a pro- 

portionate j-_hare of the factory overhead should be added to the items 

listed on Pa^e 9, Any" income" derived from the repairing of bags should, 
of course, be applied/against the cost of repairing, bags for the -mmose 
of determining the amount which should be included in factory overhead, 
or in the admini strati ve and selling expenses. 

6. According to Page 9, the "depreciation" of the finished goods 
inventory at the close of the fiscal yean* should apparently be figured 

9811 



-357- 

in the cost below which sales may not be made. This provision is ob~ 
hectionable inasmuch as it would tend to introduce losses of a specu- 
lative nature within the cost below which sales may not be made. 
Furthermore, the proposal makes a statement which conflicts with 

Office Memorandum 238-3, namely, "It is safe on the average for 

any manufacturer to figure fifty per cent depreciation on his in- 
ventory at the end of the year." 

"Depreciation of Inventory" as used herein refers to the loss 
of value in unsold merchandise attributable to style changes, broken 
or odd lots, etc. 

7. The following additional restrictions and exclusions from 
cost should be mp.de a part of the standard formula: 

a. Any amount of depreciation shown on the books 
in excess of that allowable for federal income 
tax purposes must be excluded. 

b. iTo reserve for contingencies or similar item 
which docs not represent reasonable ascertainable 

cost, but merely an estimate of uncertain 
eventualities, is to be included. 

c. Recognition, .must be given wherever necessary to the 
influence upon costs of differences in marketing methods, 
customer classes, and distance from the point of 
delivery when goods pre sold on a delivered basis. 

d. Losses on the sale of capital assets such as land, 
buildings, equipment, etc., shall be excluded. 

e. Purclip.se discounts may be applied as a reduction 

of the cost of the commodities or equipment bought. 

f . Holding company devices or affiliated relation- 
ships should not permit a member of any industry 
to evade the spirit and purpose of the no-selling- 
below-cost provisions. 

g. In the event that a member of an industry engages 
in other activities, his indirect costs shall be 
allocated to the several classes of products on 

a fp.ir or equitable basis. A cost accounting 
formula which prescribes such method of pllocation 
should not *conflict wrth the similar provisions 
of any other "cost* finding method'which may, in all 
probability, govern the accounting methods of an 
indi vi dunl ->r o due cr . 

(Signed) 0RT01T W. BOYD 
Orton W. Boyd, 
Cost Accounting Unit, 
01B:dw Research and Planning Division. 



9811 



-558- 



EXHIBIT Qj 
Jrief - Style Piracy 



9811 



-359- 
EXHIBIT "CJ" 
PROGRAM 

Section % ; 

A decision on the amendment to the Code establishing protection 
against design _pirac#*« A selection of either of the two methods (a) 
or (b)s 

(.a) Design piracy is hereby declared to "be °n unfair method of 
competition. The term 'design' as used herein, signifies designs 
artistic or ornamental nd not functional or mechanical. No member of 
the industry shall imitate or copy, or cause to he imitated or copied, 
any design original in its application to any product of the industry, 
without the consent of the owner thereof, if: 

(a) A dr '.wing, photograph or model of said design has 
been registered with - disinterested Mid impartial agency 
to be designated by the Code Authority v>dth the approval 
of the Administrator, In re, istering such design, the 
registrant shall i -dicate clearly the particular or par- 
ticulars in which such desi.ni is original in its application 
to ?„ny product of the industry, shall, in addition, submit 

a sworn st'.teuent in which he certifies that to the best of 
his knowledge and belief, such design is in fact original 
as aforesaid, and snail specify the date of conception of 
such design. Such disinterested and impartial agency shall 
accept airy design submitted for registration as aforesaid, 
and shall issue a certificate of registration to the regis- 
trant. 

(b) Said design or said article to which said design is 

- i • . applied or in which said design is embodied bears the marlc 
"Registered NBA design" or "Reg.lIRA. Code Number" , and the 
date of registration, 

(c) provided, that the prohibition herein against piracy 

of any design shall expire six months from the date of 
registration thereof. 

(d) An Arbitration Board shall be set up to settle differ- 
ences occasioned "by conflicts in design or priority of 
rights under registered designs. After all possible effort 
has been exerted to amicably settle such differences, the 
Arbitration Board shall submit to the Administrator in 
writing a statement setting forth the facts pertaining there- 
to, with recommendations as to the desired action to settle 
such differences. 

(e) Nothing contained in this Article VIII shall be con- 
strued to limit the protection afforded to designers or 
manufacturers in respect of designs under existing law. 

9811 



-360- 

(b) The Code of Fair Competition for the Ladies' Handbag Industry 
be amended "by inserting in said Code the following provision: 

(a) The Code Authority shall establish and maintain on 
terns and conditions prescribe by it, a Bureau for the 
Registration of Cri. inal Styles and designs for the purr>ose 
of defining and establishing priority of ownershi -i of such 
styles and designs, such registration to be - rima facie 
evidence of t^e originality ana ownership i for a period 
not in excess of six months from the date of registration, 
of said stylos anddesigas. 

(b) Subject to the rules ana regulations adopted by said 
bureau, any member of the indsutry may register with said 
bureau any original design which he has created. 

(c) It shall be an unfair method of competition to make, 
use, sell, or advertise a copy of any original style or 
design of another so registered, or to cause the same to 
be cone during the saic six month period, intentionally 
and with ~>rior knowledge and without express license there- 
for granted by the registered owner of the style or design. 

(d) A substantial resemblance 'of the alleged copy to the 
registered style or design shall constitute prima facie 
evidence of an intent to copy wit 1 prior lnowledge thereof. 

(e) The cost of administering the provisions of this 
section by the Code Authority shall be borne by those 
members of the industry who register their styles and 
designs with the bureau nerein provided. A registration 
fee may be charged by the Code authority sufficient to 
cover such cost, 

(f) The provisions of this section shall not Decone 
operative until the rules and regulations provided for 
nerein have been adopted by the Code Authority and ap- 
proved by the Administrator . 

(g) Rules and regulations necessary for the Adminis- 
tration of this provision of the Code rev be adopted 
from time to time by the Code Authority subject to 
disapproval by the Administrator. A violation of said 
rules and regulations shall constitute a violation of 
the Code. 

Section 2; 

All attempts to obtain Federal legislation prohibiting design 
piracy have so far been unsuccessful, and existing laws do not appear 
to provide adequate protection for cesigns. 

Codes of Fair Competition completely change the situation. 1) 
Codes make the protection selective; that is, industries wishing pro- 
tection can obtain it; and industries which do not want it are not 

9811 



■ • -361- 

cornpelled to accept it. 2) Any industry incorporating a design piracy 
provision in a Code secures legal enforcement once the Code is approved. 
3) The industry is free to set up in its ovm ranks or cooperatively 
the ro : istration machinery ueces3a.ry to obtain actual and complete pro- 
tection. 4) Arbitration can be used to insure just and speedy settle- 
ment of any controversies involving protected designs. 

Section 3 ; 

The problem ji design -protection' is not only the affair of com- 
petitors within in industry. The originator of the design, the seller 
and the public all have an interest. Only a central registration 
bureau can protect all of these interests. 

If Lhe industry sets up its own bureau, it must work out the 
standards, the procedure and the methods. Most industries have not 
the experts to do this. Consequently there would be a variety of 
methods and vide differences in planning and effectiveness. These can 
be avoided in a central registration bureau. 

The cost of maintaining a bureau in each industry to conduct an 
expert' registration search and checking system, is in many instances 
prohibitive. With a central registration bureau, the industry assumes 
little or no financial responsibility, the members who register articles 
bearing only the cost of their own search. 

The secrecy necessary to protect a registrable design is rarely 
obtainable in p.n industry where a bureau is operated by competitors. 
The slightest leak may result in the copy being on the market before 
the original can be protected. Only a central registration bureau, 
conducted under neutral auspices, assiucd confidential service. 

Section 4; 

"Design Piracy - Any member of the Industry who creates or devises a 
style pattern or a design pattern may file for official registration 
with the Pattern Registration Bureau approved by the Code Authority of 
the Industry, a sample of the style pattern or design pattern by at- 
taching thereto a registration card, which, upon application, shall 
be furnished bv the Code Authority, After such registration, 'and for 
a period of at least six (6) months, no member of the Industry shall 
in any manner or form, in the current interpretation of the Industry, 
■copy, imitate, use or deal in said style pattern or design pattern 
without the license or consent of the registrant, excepting with the 
approval of the Arbitration Board as hereinafter set forth. Said 
registration card shall include the following: the name and address 
of the registrant; the date of filing of style pattern or design 
pattern; a brief description of the merchandise, including especial 
reference to its distinguishing characteristics, ancl a description of 
the machine or machines upon which the merchandise is manufactured. 

Immediately upon such registration of the style pattern or design 
pattern, said Bureau shall make or cause to be made a full and complete 
search. If after such search, said Bureau finds that the style pattern 
or design pattern is entitled to be registered, it shall make appropriate 

9811 



-362- 

entries of registration, it shall immediately botify said registrant 
that due registration has been granted. If after such search, said 
bureau finds that the style pattern or design pattern is not entitled 
to "be registered, it shall accordingly notify the Code Authority and 
t he r e g i s t ran t . 

If the registrant is not satisfied with the finuin, of said Bureau, 
the Code Authority, upon request b; the registrant, shall refer the 
matter to an Arbitration Board for final determination. This Board 
shall consist of three members? one to be designated by the Code Author- 
ity; one to be designated by the re ; istrant; and the third shall be the 
Administration Member of the Code Authority to serve as Umpire. If the 
Arbitration Board determines that the style pattern or design pattern 
is entitled to be registered, said Bureau shall immediately complete 
registration." 

Secti on 5; 

.>. ; :'.--rn to be decided by the committee are the following: 



< 



l .1 'stly, it would decide preliminary questions which lie 
'_rely within the scope of the industry such as: 

/hat constitutes registrable 'designs? 

■-'or how long' a period should protection be afforded 
registration? 

./) Should such registration be renewable and if so for 
how. long a eriod? 

d) Should owners of designs be privileged to lease them 
to other members of the industry? 

2. Secondly, the committee would decide whit form of registration 
was best suited to the industry and whether to set up an 
individual Bureau or to use the existing Industrial Design 1 
Registration Bureau. 

3. If the decision' is made to use the existing Bureau, the third 
function of the committee woulc 1 be to arrange with the staff 
of the Bureau technical details of registration such as fees, 
time allowed for searching the files', ■ id ather matters af- 
fecting the process of registration in the industry. 



)811 



-363- 



CONTEUTS 



code provision 

problem 0? pes igf piracy 

aijebigah arbitration society plan 

the haydeh plan 

tee el/jell plan 

ebseahch & planning department n.r.a. 

procedure iii eaitdlihg cases 

provisional rules of pfe design registration bureau 

fetfcds and costs of fesigf registration 

comments fy code director 



9311 



-364- 

There is presented herewith lor consideration "by the committee various 
methods by which control of Style Piracy tr.if.ht "be established for the 
industry. In order that tie industry might obtain a method best fitted 
for the Ladies' Handbag Industry, we requested Be- artments of the Adminis- 
tration to write a provision that would be acceptable to the Adminis- 
ts"'tiion| and at the same time give the industry the opportunity to es- 
tawj.ish and control this important function. There ore -resented here- 
with three provisions. 

Provision Ho. 1 suggested by the Arbitration Society of America does 
not set up in detail any rules and regulations, but rather a method 
of procedure. It is not certain that this provision would be accepted 
by the Department of the A'.. minis tration since it does not exclude in- 
fringement on patterns and copyrights. 

Provision ho. 2 was rendered by Mr. Howard I-Iayden of the Planning and 
Research Le-artment nf the Administration. This provision is more ex- 
plicit and gives greater details for the method of establishing and 
maintaining of such a bureau for registration. This provision would 
be acceptable to the Administration. 

Provisi ■ '-. .y-s written by Mr. Elwell of the Legal Department of 
the - u: -:■ h :n and we believe one most suited to our industry. 
Mr, 21 » 11 rally is interested in the subject of Style Piracy and 
he n L\ - . > y h understanding of what industry requires to be pro- 
tect:':. ."-• ■ ; .-\e Piracy. Mr. Elwell undertook to -rite this pro- 
vision i;o ■ ■ "■ car particular needs and we are of the opinion that it 
cov ..' ;.■''; as possiole the requirements of our industry. This 
prov:' ■ .y. ■ be acceptable to the Legal Department of the Adminis- 
tr&.T,: j..- , 

We have hereto as rart of our report information furnished by various 
sources who are no- enga, ed in the wor?: of registration of designs 
for various industries. These reports outline the methods and machinery 
for the establishment :•. registration for styles and designs which are 
now being operated by various industries. Also a special report from 
the Design Registration Eureau containing an estimate of the costs and 
the manner of applying these costs to the members of the industry who 
wish to avail themselves of the protection of the Bureau. 

It must be understood that the only method of enforcement is the Code 
of the Industry and that in order to establish Style piracy for the 
industry, that it will be necessary to ash and obtain from the Adminis- 
tration proper amendments to the Code as provided for ~^>y the Code. 



A. Hittenthal 

Code Director 



9811 



-365- 
ARTICLE VIII, Section (j) 



To undertake, in conjunction with the Code Authorities of related 
industries, an investigation of style piracy and to recommend to the 
Administrator, within a reasonable period of time, appropriate means 
for the regulation and control of style piracy, which recommendations, 
upon the approval of the Administrator and after such notice and hear- 
ings as he may prescribe, shall become effective provisions of this Code, 



THB PROBI EII OP DESIGN PIRACY 

Industry has long struggled with the problem of design piracy, and 
the protection of designs is now acknowledged to be a vito.1 factor in 
commercial life. The design pirate is recognized in many industries 
as a menace to progress and to profits. Thousands of manufacturers 
who employ a designing staff or buy original designs have to suffer 
heavy losses by the theft of those designs and their reproduction in 
inferior material at a cheaper cost. The widespread practice of steal- 
ing designs does nothing to "stimulate original creations; on the con- 
trary it cheapens and debases them, and its cost to industry is es- 
timated at millions of dollars annually. 

As a result of a survey undertaken at rhe request of a number of 
industries, the American Arbitration Association, which is interested 
primarily in the settlement of industrial controversies, established 
a National Council on Design protection. This Council affords a neutral 
medium through which trade associations can work out their design piracy 
problems under Codes. 

The work of the Council is directed by men and industries vitally 
interested in the protection of designs. Finding in operation an In- 
dustrial Design Registration Bureau, originated by the rational Feder- 
ation of Textiles, Inc., which was open to all industries, the eouncil 
established cooperative relations .and has put forth the following plan 
for the consideration of industries having or intending to obtain piracy 
provisions in Codes. 

Design Pira cy P rovisions in C odes 



Under this Plan, the first important step is to insert a design 
piracy clause in the Code; and if the Code is already approved, to 
propose it in a supplemental Code. The Council has compiled the 
clauses from approved Codes for submission to industries intending 
to use clausos, but recommends the following as being simple and 
effective : 

ho member of the industry shall imitate, simulate or 
appropriate any original or unique design or style or 
any trademark or name or brand registered with the 
industry or its designated agency; and any such imi- 
tation, simulation or appropriation shall constitute 
an unfair trade practice and a violation of this Code. 

9811 



-366- 
Central Industrial Design Regis tr-- tion bureau 

The Council "believes that the next step is for the industry having 
such protection to use a central Industrial Design Registration Bureau. 
For all industrial groups having the conr.ion -problem of design pr otection 
such a bureau is entirely practical, expedient and less costly then the 
establishment of a separate bureau in each industry for the following 
reasons: 

1. The problem of design protection, is not only the affair of 
competitors within an industry. The originator of the design, the seller 
and the public all have an interest. Only a central registration Bureau 
can protect all of these inter ests. 

2: If each industry sets up its ivm bureau, it must work out 
the standards, the procedure and the methods. Most industries have 
not the experts t3 do this. Consequently there would be a variety of 
methods and wide differences in planning ana effectiveness. These can 
be avoided in a central registration bureau. 

3» The cost of maintaining a bureau in each industry to conduct 
an expert registration search and checking syster.i, is in many instances 
prohibitive,, Kith a central registration bureau, the industry assumes 
little or no financial responsibility, the members who register articles 
bearing only the cost of their own search. 

^•o " s secrecy n&cessary to protect a registrable design is 
rarek :■! fcaina'Sls in an industry where a bureau is operated by com- 
petiro'" . . ' _ ■ slightest leak may result in' the copy being on the market 
before the irigiittl can be protected. Only a central registration bureau , 
cone- bed vji.de r neutral auspices, assures confidential service. 

Fro tection of So sig ns in the Textile Field 

The success of the Industrial Design Registration Bureau of the 
Rational F; o.-. rax:'. on of Texti:les, Inc., 'has proven. that the control of 
design piracy is a realizable ideal. A practical system, such as that 
now in use --A the Bureau, can be utilized, oy an industry desirous of 
protecting its designs. 

Five years ago, the stealing of designs in the silk indiistry was 
common practice.. Now a. case of design piracy is a sensational story, 
for the Bureau has been almost a hundred percent successful in its 
rotection of original designs. : • 

The necessity for registration is apparent in every industry 
having a design piracy problem. The existing Industrial Design Regis- 
tration Bureau is now available to other industrial groups. It operates 
this way: 

First Step Towards Registration 

Operation of a registration service for designs in any industry 
is possible only with the agreement of all members of an industry to 
submit all designs to a central clearing house. Should the number of 

9311 



-367- 

designs in use "be overwhelmingly large, a committee representing the 
industry may agree that only designs in use after a certain date are 
to be submitted. 

Procedure at the Bureau 

• 
(Textile Division) 

(a) Secrecy - When the owner brings the colored sketch of the 
design to the Bureau, it is given to the entry cleric who removes the 
name and substitutes a symbol. The sketch is then sent to the search- 
ing room for comparison. The entry clerk is* the only person in the 
Bureau who knows to whom it belongs. There is no chance of a leakage, 
- no names inadvertently overheard, no buyers seen' by chance in the 
offices. 

(b) Search and Comparison - When it reaches the searching room, 
the design is first photographed. Then rt is classified under various 
general headings - geometrical, floral, etc., and cross-referenced to 
insure accuracy in search. The photograph next goes to the expert 
searchers who compare it with previously filed entries of its type and 
classification. If no conflict is discovered, the sketch is stamped 
as original, sent back to the entry clerk and returned- to its owner. 
The whole operation takes forty-eight hours, A day and a night staff 
of searchers is employed, for there are at present some forty-four 
thousand designs on file. 

(c) Time Limit Regulation s - When the owner receives his sketch 
again, he must be "prepared to print it and return a finished "swatch" 
of the material to the Bureau within thirty days. This is to prevent 
manufacturers from buying up all the likely designs for years ahead 
and to insure that ever~> r design they register is intended for immediate 
use. Registration is good for one year and may be extended to two. 

(d) Procedure on Rejection - If the design appears to conflict 
with a previous entry, it is checked three times before final rejection. 
Distribution of color is- taken into account, slight changes in line or 
contour are not considered but every care is taken to-^ive a fair 
decision on the basis of substitution from the vi ewpoint of the ave rage 
buyer or consumer ." 

An owner may occasionally question the Bureau's rejection. In 
such cases, the conflicting entries are shown to a committee of seven 
representing different branches of the industry. Before being sent to 
the committee, even the symbols are removed from, the entries as an 
absolute safeguard. For a decision five members are required to vote 
and the decision 'is final when given by a majority. 

(e) Pro visiona l Rules - A set ox' Provisional Rules of the national 
Council on Design Protection. has been drawn up, and these rules con- 
stitute part of this plan. 

Pro cedure for Other Indust ries . 

While the system set forth above has been found successful in the 
textile and leather fields, the' rules can be altered to meet the needs 

9811 



-363- 

of any industry. A Committee on Design Protection consisting of members 
of the industry may work out a special technique suited to that particular 
industry. Such a, committee would have three functions: ■ 

1. Firstly, it would decide preliminary questions which lie 
entirely within the scope of the industry such as: 

a) What constitutes staple or standard designs. (Shese 
should "be separated by a committee from the regis- 
trable designs . ) 

b) For how long a period should protection he afforded 
by registration. 

c) Should such registration "be renewable and if so for 
how long a period. 

d) Should owners of designs be privileged to lease them 
to other members of the industry. ■ 

2. Secondly, the committee would decide what form of registration 
was best suited t'o the industry anc 1 whether to set up an individual 
Bureau or to use the existing Incus trial' Design Registration Bureau. 

3. If the decision is made to use the existin Bureau, the third 
function of the committee would be to arrange with the staff of the 
Bureau technical details of registration such as fees, time allowed 
for searching the files, and other matters affecting the process of 
registration in the industry. 

How Designs are Protected . 

It will "be seen that the system does more than merely assure a. 
priority right in case of litigation. It actually prevents copies - 
from reaching the market . Each accepted entry is stamped before it 
leaves the Bureau, and that stamp is an assurance that subsequent 
con flicting entries will "be rejecte d. The printers, dyers and engravers 
will not work on a design unless it bears the stomp if the Bureau. 

This arrangement was in full force two years "before Codes came 
into effect. It should certainly be possible to evolve a. similar 
system in other industries needing protection or to arrange to have 
them use the present system, especially no?/ that C">des of Fair Com- 
petition offer to industry the opportunity it has long awaited to 
establish firmly the "basic procedure of fair practice-. 

Situation Changed by Codes 

All attempts to obtain Federal legislation prohibiting design 
piracy have so far been unsuccessful, and existing laws do not appear 
to provide adequate protection for designs. 

Codes of Fair Competition completely change the situation. 
1) Codes make the protection selective; that is, industries wishing 

•protection can obtain it; and industries which do not want it are not 

9811 



-369- 

compelled to accept it. 2) Any industry incorporating a design piracy 
provision in a Code secures legal enforcement once the Code is approved, 
3) The industry is free to set up in its own ranks or cooperatively the 
registration. machinery necessary to obtain actual and complete pro- 
tection. 4) Arbitration can be used to insure just and speedy settle- 
ment of any controversies involving protected designs. 

Further Information 

The national Council on Design Protection of the American 
Arbitration Association, 521 Fifth Avenue, iTew York City, will be 
glad to furnish further information or to provide an escort for 
those desiring to see the Industrial Design Registration Bureau 
in operation. 



"0 member of the Industry shall imitate, simulate or appropriate 
within six months from the date of its registration or any extension 
thereof, any original or uniojuo design or style or any trade-mark or 
name or brand registered with the Industry or its designated agency, 
and any such imitation, simulation or appropriation shall constitute 
an unfair trade practice and a violation of this Code. 

Style Piracy or Pi r acy ..of De sign 

The Code Authority may establish or designate a Bureau of Design 
Registration and organize a Committee for the interpretation of design 
in the ciirrcnt acceptation in the trade/ industry, and no member of the 
trade/ industry shall usurp or make use of any design, drawing, pattern, 
plan, style f eature , or distinguishing characteristic which has been 
registered with such lureau; or any such design which lias been sub- 
mitted to a prospective customer by a competitor and is dated and 
rightfully and plainly marked as iiaving been -created or devised by and 
being the property of such competitor and which lias not been purchased 
by such prospective customer; or reproduce offer for sale or sell any 
article of such design within a five year period a.fter its original 
production. 



Howard Hayden 



5811 



c - 37 °- 

o 

p NATIONAL RECOVERY AD; 'III I STRATI 0"_ T 

7 

WASHINGTON, D.C. 

May 32, 1934. 



hir. Max Derkowitz 
303 Fifth Avenue 
New York City 

Dear Mr. Derkowitz: 

I note in a public Release, which is enclosed, that 
the Ladies Handbag Industry is desirous of reorganizing its Code 
Authority. 

As I promised you when you were here, I am now out- 
lining a procedure for handling the registration of design and the 
steps to be taken in pr^ventin^ any member of the industry from 
usurping any design that has been regularly registered. Of course 
this procedure is subject to such modifications as may ba roc« s snry 
or desirable in your particular industry. Conditions are dis- 
similar in any two Industries and what may work well in one may 
not be so successful in the other. This procedure, however, lias 
met with a general approyal of the Administration and it is sug- 
gestive, at- least, if not entirely applicable to be used exactly 
as it has been crafted. 

VJhen you were hero, I gave you a suggested Code 
provision to cmsider. Of course, this procedure is purely the 
by-laws or rules to carry out tae Code provision. This procediire 
should not be written into the Code, but adopted as a resolution 
bytbeCoce Authority and ^resented to the Administrator for approval. 

Lo not aesitate to consult with ine on any matter 
that you may feel I can be of help. 



Sincerely yours, 
(Signed) Howard Heyden 



NRA Trade Practice Consultant, 
Compliance Division 



hh/hr 

Enclosure, 



)811 



-3T1- 

article ix 

KESISThATIOll OF DESIGNS 

Section 1. Design piracy is hereby declared to be an unfair 
method of competition. The term 'design' as used herein, signifies 
designs artistic or ornamental and not functional or mechanical. No 
member of the industry shall imitate or copy, or cause to be imitated 
or copied, any design original in its application to any product of 
the industry, without the consent of the owner thereof, if: 

(a) A drawing, photograph or model of said design 
has been registered with a disinterested and impartial 
sogency to be designated by the Code Authority with the 
approval of the Administrator. In registering such 
clesign, the registrant" shall indicate clearly the par- 
ticular or particulars in which such design is original 
in. its application to any product of the industry, shall, 
in addition, submit a sworn statement in which he certifies 
that to the best of his knowledge and belief, such design 
is in fact original as aforesaid, and shall specify the 
date of conception of such design. Such disinterested and 
impartial agency shall accej.it any design, submitted for 
registration as aforesaid, and shall issue a certificate 
of" registration to the registrant. 

(b) Said design has been offered for sale, or said 
design has been applied to or embodied in articles pro- 
duced unter this Cods or any other code affecting similar 
products for sale or public distribution. 

(c) Said design or said article to which said design 
is applied or in which said design is embodied bears the 
mark "hegistered NBA design" or "heg. NRA Code Number", 
anc the date of- registration. 

Provided, that the, prohibition herein against piracy of any 
design shall expire sir, months from the date of registration thereof. 

Section 2* An' Arbitration Board shall be set up to settle 
differences occasioned by conflicts in design or priority of rights 
under registered designs. After all •Possible effort lias been exerted 
to amicably settle such differences, the Arbitration Board shall sub- 
mit to the Administrator in writing a statement setting lorth the facts 
pertaining there bo, with recommendations as to the desired action to 
settle such differences. 

Section 3. Nothing contained in this Article IX shall be con- 
strued to limit the protection afforded to designers or manufacturers 
in respect to designs under existing law. 



9811 



-372- 

PR0CEDU11E III HAlTbLING CASES, 0? USURPATION 
:■■-..: OE DESIGN 



"Design Piracy - Any mrmber of the Industry who creates or clevises 
a style pattern or a resign .pattern may file for official registration 
with the pattern Registration Bureau approved "by the Code Authority of 
the Industry, a sample of the style pattern or design pattern "by at- 
taching thereto a registration card, rhich, upon application, shall he 
furnished 'by the Code Authority. After such registration, ana for a 
period of at least siz (6) months, no member of the Industry shall in 
any manner or form, in the current interpretation of the Industry, copy, 
imitate, use or deal in said style pattern or design pattern without 
the license or consent of the registrant, excepting «rith the approval 
of the Arbitration Board as hereinafter set forth. Said registration 
card shall include the following: the name and address of the regis- 
trant; the date of filing of style pat-tern or design pattern; a "brief 
description of the mere- Andise, including especial reference to its 
distinguishing charactf dstics, and a description of the machine .or 
machines upon which the merchandise is manufactured. 

Immediately upon such registration of the style pattern or design 
pattern, said Bureau shall make or cause to he made a full and complete 
search. If after such search, gaiJd Bureau finds that the style pattern 
or design pattern is entitled to "be registered, it shall make appro- 
priate entries of registration, it shall immediately notify said regis- 
trant that due registration has "been granted. If after such search, 
said Bureau finds that the style pattern or design pattern is not en- 
titled to be registered, it shall accordingly notify the Code Authority 
and t lie regi s t ran t . 

If the registrant is not satisfied with the finding of said Bureau, 
the Code. 'Authority, upon request by the registrant, shall refer the 
matter to an Arbitration Board for final determination. This Board 
shall consist of three members; one to be designated by the Code Author- 
ity; one to be designated by the registrant; and the third shall be the 
Administration member of the Code Authority to serve as Umpire. If 
the Arbitration Board determines that the style pattern or design pattern 
is entitled t o be registered, said Bureau shall immediately complete 
registration." 



jjs -'-. "': ■>. =;< # >y * 3fc * sfc * ^e 



98U 



MP 1.1934 -373- 

S T A :!EA^ :■ S 
of 
TEE lUTIOiTAL COURCIL FOR BLSIGi' FROTRCTIOU 
For Design Regi strati on Service 



1. Ago ointment of Co/ . imittee on Design Rcgi strati on : 

A Committee of three or five persons shall be elected by each 
industry. The duties ";f this Committee shall he 

a. Prescribing of rules one" regulations for the 
conduct of the service under the guidance and 
with the advice of the staff of the Design 
Registration Bureau. 

b. Acting as an .--.ppeal Committee in case of dispute 
regarding judgment of the Bureau as to conflict 
between designs', 

.0. Rule s and Regul ations; The Committee shall, o'a the 
basis of tne need? of each industry, determine for the guidance 
of tne Bureau, the following policies: 

a.-.. The length of tine t ) be , iven the Bureau for 
passing up^.n the design. 

b. The period oi protection (i.e., one pear; 
five pears, etc.) 

c. 'That shall be c nsidered staple or standard 
designs - that is, those not rightfully monopol- 
ized by one firm. 

d. Determination of the form in which designs 
will be submitted to the Bureau. 

3. Establishment of a Design Pile: To inaugurate design 



registration service, the following steps are necessary: 

a. A request shall bo issued by the authorized com- 
mittee to everyone in the industry, requesting 
the filing with the Bureau by a certain date, 

of r^ll designs being usee" by .'each individual owner. 

b. A classification system for grouping the designs 
according t major types shall be prepared with 
the mutual cooperation of the Committee and the 
Bur e au ' s s t af f . 

c « The Committee will determine the oasis upon which 
the Bureau will accept a.s re, isterable, designs 
received in the initial lot, that is, whether all 
but those previously classified as staple or stand- 
ards shall be registered, in which event, duplico.tes 

9811 



-374- 

of registrable d-sig'.s shall b- d~cid"d or. 
th r 'basis of priority of- r c ipt or such oth-r 
"basis as th- Committee ma" d cid- to b- fair 
a. d -quitabl , or, to accept for r-~gistrat3o r. 
oily thos" d-sig'.s \ot duplicated i._ tlr initial 
■ coll' ctio'... All others to b- co : .sid-r-d as 
stapl- r or standard at tla tim of -stablishi' g 
tlr Bureau. (it may b~ that i.. this coll ctio.., 
th' r- will b.- jatt r:.s classified as staple or 
standard, which lat-r vrould b- ".titled to regis- 
tration, if submitted without duplication..) 

4, S" ttl'm-.'.t of Disputes R yarding R'gistrat io: or Us r 
of R-sig'-.s : Disput's r gardii.g r j"ctio;.s mad^ by th- Bureau shall 
br r-f.-rr d to th- governing committ-- for th- i .dustry upo:. th- 
rqu-st of th- owner of tlr design, A f - shall V fix-d by the 
Committ-- for th- h-ari g of such appeals » in ord*-r to cov-r the 
additio: .il cost of handling th d" tails, and also to -limi.at^ 
obj-ctio s that :r- not mad- i good faith. 

I., th- event of th- ownership of a d' sig: . b'i'.g disputed, or 
whar^ arra g~me .ts ar- to b' made for cross-lie si g of a certain 
d-sigv. b-tv--: or or mor- parties, th- matt-r shall be adjusted 
by arbitration, i: . accordance with th- rul-s of th- American. 

Arbitration. Association.. 



9Bli 



-375- 

PROVI SIGNAL RULES ...",. .... » 

• of 'the , .' . .'.* 

■. - ' . NATIONAL COUNCIL OI T DESIGN PROTECTION '■ 

for the • '''•■■' 
DESIGN REGISTRATION BUREAU 

The National Council an Design Protection adopts 
the.f ollowi/ng Rules of Procedure a far the registra- 
tion of original designs » ' tirade names and trade- 
•■"Viiarlis in the Design Registration Bureau. 
.' - ' / 
1. • Application f or Sefrvice^ oAhy trade association or industrial 
grottp operating under a Code of Fair Competition which contains a 
provision constituting the imitation or simulation of original designs, 
trade names or trademarks -an unfair trade ^practice , or any such associ- 
ation or group establishing such standards may apply to the Council or 
to the- Bureau' for the. use of its facilities for its members. Extension 
of, the ; 'use of facilities to such members shall be through the medium of 
such association o:- group. The Council shall anprove : of such application 
before the service of the Bureau is made available; -and such trade 
association or'gr.o,up subscribes to these Rules for its members. 

.II.-.' Institution of Servic e: Each trade association or industrial 
group applying for. .service shall obtain from its members*.a complete 
record of all designs, trade names or marks owned by such members, 
before a specified date, and shall sort, these according 'to 'type and 
date and shall. file them with the Design "Registration Bureau, 

III. Definitions ; Each- association, or group, .within the terms of its 
industry, shall define the ne'ahing of original, design, or pattern, 
what shall constitute a staple 1 , 'and' Shall.'. fix. the • period of time for 
which registration shall, run "for the protection of a design and the 
terms of its renewal. ••'-*' 

IV. Requir ements, for Registration; Any member of an industrial group 
entitled to apply .for.registration of a design, trademark or trade name, 
shall accompany .such application with a sample, original sketch, copy 

or model for purposes of identification and such application shall con- 
tain the name and address of the person and if a firm in addition there--; 
to, tne signature of the firm's officer or authorized employee and the 
legal seal if the applicant is a corporation, together with such other 
information as the 'Bureau may require. Each application shall be accom- 
panied by the fee fixed by the Bureau and the association or group for 
such services. * 

V. Eees and Expenses; The fee" ''to be paid by each applicant for each 
article submitted for registration shall be fixed according to schedule 
by the Bureau and association or'' group, and may be adjusted with their 
joint approval or in the discretion of the Bureau. If the design is 
not registered, part of the fee'Snali be returned-, according to the 
above schedule. The Bureau and -the 'association or group may also fix 
the initial expense for installing" whatever additional facilities may 
be necessary to institute the proper service for that industry. 



9811 



-376- 

VI. Proceedings: All designs, trade smarks and names submitted for regis- 
tration are held in absolute confidence, and no one but authorized 
members of the Bureau staff shall be permitted to examine the files or 
have access to the filing rooms. Immediately uoon receipt of the ap- 
plication, together with the date required, it is examined by esoerts, 
checked with the files and a thorough search made to determine whether it is a 
duplicate or similar to one already registered. If it is subject to 
registration, a photostat copy is returned to the apolicant, with a 
certificate of registration; if it is not subject to registration, the 
article is returned to the apolicant stating the reason therefor. 

Appeals from the decision of the Bureau may be taken in the manner here- 
inafter provided for. 

VII. Design Labels ani. Stamps: Any applicant who is granted a registration 
duly certified by the Bureau is entitled to use the design label or stamp 
of the Bureau • on such articles as are registered. Upon application, these 
will be furnished by the Bureau at a price to be agreed uoon. 

VIII. Special Instructions : The Bureau may issue from time to time 
special instructions of a technical nature to trade associations or 
industrial groups dealing with such matters as making of samples, draw- 
ings and sketches and models, wrapping and marking of the above, methods 
of notification and similar matters for each industry for distribution 
to its members, 

IX. Appeal sr Any dispute regarding rejections by the Bureau shall be 
referred to an Appeals Committee established by the Council for the 
Bureau, upon the reauest of the apolicant whose design was rejected, 

A fee shall be fixed by the Appeals Committee for the hearings in order 
to cover the additional cost of handling the details and also to elimi- 
nate objections that are not made in good faith. The members of this 
Committee shall serve without comoensation. 

Whenever the ownership of the design or mark or name is in contro-r 
versy or when arrangements' are to be made for the cross-licensing of a 
design between one or more 'parties, the matter shall be submitted to ar- 
bitration in accordance wi + h the rules of the American Arbitration Asso- 
ciation, 

X. Complaints: Any comolaint regarding the imitation, simulation or 
copying of a design, trademark or trade name, shall be filed with the 
Bureau which will immediately institute an inquiry and endeavor to make 
an adjustment in accordance with the findings, Uoon the failure of such 
adjustment, the matter shall be reported to the Code Authority of the 
industry as constituting a violation of the Code, and for settlement it. 
may be referred to arbitration under the Rules of the American Arbitra- 
tion Association upon request of both parties, 

XI. Committee: Each industrial group or trade association shall estab- 
lish a Design Protection Committee to cooperate with the Bureau in the 
administration of these Rules and to recommend alterations therein. The 
Committee may recommend the establishment of a separate division in the 
Bureau for handling registrations referred by its members, but such divi- 
sion shall be under the guidance and supervision of the staff of the 
Bureau and subject to these Rules. 

9811 



-377- 

XII. Representation on Council : Each trade association or industrial 
group using the facilities of the Bureau shall "be entitled to one repre- 
sentative on the Council, such representative to be chosen by the asso- 
ciation or group, 

XIII. Amendments : These Sales may be amended by the Executive Committee 
of the Council on request of the association or group, and a hearing 
thereon shall be granted at its request. 



-378- 

TEXTILE DESIGN REGISTRATION BUREAU 
468 :~OURTH"AVEirUE ;i ' ■ 
HEW YORK, IT. Y. 



■•:...;,■■■-■ '■■'-■"■'.■ June 11, 1934.; 

Mr. A. i.ii ten thai 

Code Administrator, Handbag Industry 

303 Fifth Avenue 

Her York, IT, Y. 

Dear L'r. Lit en thai: 

You have asked me to outline for you briefly our plan for design regis- 
tration as re follow it with the Industrial Design Registration Bureau. 
First of all, I night say that this plan is essentially to prevent 
piracy and therefore it involves a method of filing photostatic copies 
of designs which form 3 filing system whereby new designs after they are 
received, are compared with those already filed and given or denied 
registration. 

As you stated that the Handbag Industry did not want complete protection 
at this time, that is, compulsory submittal of every design, the service 
in this case would consist of receiving such designs as the industry 
desired to have registered, thus establishing a date of first use which 
later, if d.esired, could be used by your Code Authority as a means of 
enforcing your piracy clause, forbidding, I understand, the copying of 
designs in the industry. 

The handbags are submitted in whatever form you wish, together with in- 
formation as to what are considered the "'registera'ble features;" in 
other words, what particular features of the bag are considered new 
and different. 

As in every other industry, we assume that there are certain staple 
types of bags on which no one is entitled to protection. These would 
be classified by the Bureau as staples. The extent of protection would 
be that of substitution by the average layman in accordance with pre- 
vious precedents laid down in Patent Office cases. 

The charge, subject to confirmation by our Committee on Design Regis- 
tration, would be probably $5 a design with a fee of $2 if the design 
is rejected. This, we believe, would cover the expenses of the Bureau, 
bat it is our custom, when extending this service, to require a guaranty 
from the organization requesting it to the effect that any deficit at 
the end of a specified period shall be met by the industry, and that 
this .guaranty shall also prevail if, at any time, the service is dis- 
continued by the industry. 

We do not believe, however, that there would be any occasion for the 
exercise of this guaranty if the fee is $5. I informed you the other 
day that the fee was $4, but I find now that the minimum for which we 
will take a new service will be $5, 



9811 



-379- 
Mr. A. Mitenthal -2- June 11, 1934 



I should toe very glad to give you additional information if desired, 
and enclose a set of standards for design registration service which 
was prepared for the use of other industries desiring to avail them- 
selves of our work. 

If your organization is interested, I shall toe glad to take the matter 
up with our Committee on design Registration at the earliest or>r>ortuni ty. 



Yours very truly, 



(Signed) I. L. BLUNT 
Director 



ILB :MDP 
Enclosure 



9811 



-330- 



EXHIBIT R 
Compliance Report 



9811 



-381- 
EXHI3IT R. 

COMPLIANCE ANALYSIS,. NO 900 

MEMORANDUM TO L. S. Bendheim. 554 Barr Bldg . " ' ' 

FROM: J. J. Reinstein, Acting Chief, Coordinating 3ranch, 

Compliance Division, NBA 

October 24, 1935 

Labor Analysis of Complaints under Code Ladies Handbag Ind. 

1. Pace sheet Carbons of Complaints docketed at N.R.A. State Offices 

Dates range from July 25. 1934 to May 24. 1935 

Total number of face sheet carbons 109 

(One face sheet may contain several violations) 

Type of Violation 

"age Group 

Art. IV. Wages below minimum 

Art. IV. Sec. 4 Piece work fails to equal minimum 

Art. IV. Seeking back r.'age 

Art. IV. Sec. 5 - Reducing wages _, 

Art. IV. Failure to pay correct overtime 

. Hour Croup 

Art. Ill Hours exceed maximum 

Art. TTI - Sec. 5. Total no. hours for 2 employers 

exceed max. 

Other Violations 

Art. TV. Par. 10 Home TTork 

Art. V. Sec. 5 Improper Class of Employees 

Art. V, Par. 1 Employing Minors 

General Labor Provisions 



Total number of complaints filed 
Complaints filed by : 



No. of 


Complaints 


83 


71 


5 


3 


1 


3 


58 


56 




2 


19 


7 


3 


6 


3 




160 



Code Authority 20 

Individual and Others 87 

N. R. A. Office 2_ 



109 



DEFINITIONS: 

A face sheet is a summary from prepared by a State Office to be placed on top 
of the case file w hen a. complaint is accepted for investigation. It shows the 
state office receiving the complaint, the docket number, name of respondent 
and complainant, the code violated, and gives a summary of the type of alleged 
violation, specifying the article and paragraph of the code provision. 

Compiled by 

Date 

9811 



, o„ 



Memorandum To Mr. L. S. Bendheim, 524 Barr Bldg. 

From: J. J. Reinstein, Acting Chief, Coordinating Branch, 

Field Division, N-. R« A. 

Subject: Summary 6f IC.R.A. State O^'ice complaints 

Ladies II? ndbag 



CODE 



i35 


LABOR 
3/21/34 
207 
82 


TRADE PRACTICE 
5/26/34 




28 




16 




-61—- 


5 




17 


2 






. 


■-■"■ 








, 





Cumulative total -through Kay 27, 1935 

Date of earliest complaint 

Total docketed 

Investigated complaints Adjusted 

No violation found 

Bookkeeping rejections 

Referred to District Attorney 

Federal 

State 

Compliance Division, or 
Regional Office 

Code Authority, in first 
instance, prior to June 15, 1935 

N.R.A. insignia removed by State 
Directors in service trades 

On hand, May 27, 1935 

DEFINITIONS: 



These are cumulative totals of code complaints handled by N.R.A. State 
Offices from the date of the earliest complaint through May 27, 1935, 
Series as a rhole begins November 11, 1933. Complaints handled by code 
authorities are not included in this summary. • ■ 

Complaints docketed include complaints received and accented for investiga- 
tion. Prior to June 16, 1934 all receipts including complaints immediately 
rejected were reported in the intake figures. 



13 



34 



9811 



-383- 



Investigated complaints , are reported adjusted when a certificate of com- 
pliance is secured. Investioged cases in which no violation is found have 
been reported separately since June 16, 1934. Formerly they were included 
in "adjusted" figures. 

Bookkeeping rejections: Complaints cleared from the docket for this code, 
because of referral to Code authorities or other special adjustment agencies 
after docketing. Complaints dropped from the special suspense ifile with 
the permission of the Field Representative are also included. 
Referred to Code Authority in first instance. Prior to June 16, 1934 
complaints referred to code authorities in the first instance were included 
in the intake, and reported as referred to the code authority. After that 
date complaints referred to officially authorized code authorities were 
reported on another form, and were not shown here. 

K.R.A. insignia removed by State Directors, are reported only for service 
trades in which trade practice provisions are suspended, and in the Res- 
taurant trade. 

Date 13/24/35 

Statistics Section 
Field Division 



9811 



•384- 



MEMORANDUM TO Mr. L. S. Bendheim 



524 Barr Bldg. 



FROM: J. J, Reinstein, Acting; Chi sf, Coordinating Branch, 

Field Divirion, N. R. A. 

Subject: Summary of Comnliance Division and Regional Offices cases (a) 

Lad ies Ha ndbag , . CODE 



LABOR 



TRADE PRACTICE 



LABOR AND 
TRADE PRACTICE 



Docketed 

Closed by Adninistrat ive 
action (b) 

Referred to Litigation 

Blue Eagles Removed 

On hand May 27, 1935 



13 



121.. 











(a) Prior to January 1, 1935, cases T "ere docketed in ConrDliance 
Division, TT ashington, 

(b) Adjusted or drccr^ed. 

This is a report of cases referred by F.R.A. State Offices or by the 
Code Authority to the Co"ipl'*sn r.e Division, or, after January 1, 1935, 
to the Regional Offices for soeci^l administrative action. See also 
the report showing cumulative totals of comolaints under the Code handled 
by K.R.A. State Offices. 



Date 10-24-35 



Statistics Section, 
Field Division. 



9811 



-385- 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Fifth Avenue 
New York 



STATISTICAL REPORT 



September 30, 1934 



Number of Investigation Made 567 

Non-Compliance Ca.ses pending 58 

Non-Compliance Cases closed 105 

Restitution: 

Number of firms 43 

Number of individual employees 814 

Total amount paid -$11,393.53 

Approximate amount pending $ 8,000.00 

Number of Manufacturers 325 

Number of contractors 173 
Approximate Number of Workers Employed 

in the Industry 15,800 

Number of Phone Calls Per Day 42 

Number of personal interviews per day 36 

October 31, 1934 

Number of Investigations Made 807 

Non-Compliance Cases pending 72 

Non-Compliance Cases closed 130 

Restitution 

Number of firms 47 

Number of individual employees 901 

Total amount paid $13,024.22 

Approximate amount pending $10,200.00 

Number of manufacturers 498 

Number of Contractors 173 
Approximate Number of workers employed 

in the Industry 15,800 

Total Number of labels distributed as of 

November 2, 1934 15,533,800 

Number of phone calls per day 45 

Personal interviews per day 39 



9811 



— hxJd** 



CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Eiith Avenue 
" New York 



STATISTICAL REPORT 



November 30, 1934 



Investigations — < 

Number previously reported 807 
Number made during 1 November ■ .274 

Total 1021 

Number ^Ton-Compliance Cases Pending 72 
Number Closed During November 90 

Restitution — 

Number of firms 53 

Number of Individual Employees 934 

Total /mount Paid $13,347.39 

Approximate Amount Pending $10,OOC.OO 

Analysis of Industry — 

Number of Manufacturers . 332 

Number of Contractors . 165 

Approximate Number of Workers Employed 15,800 

Total Number of Labels Distributed 19,528,800 

Office Routine — 

.Number of Phone Calls per day • 48 

Personal Interviews per day 41 



CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Fifth Avenue 
Ner York 



STATISTICAL REPORT 



Investigations — 

Number previously reported 
Number made during December 
Total 



1021 
326 



1347 



Number Non-Corroliance cases Pending 
Number Closed during December 

Restitution — 

Number of Firms 

Number of Individual Employees 
Total Amount Paid 
Approximate amount sending 

Analysrs of the Industry 

Number of Manufacturers 

Number of Contractors 

Approximate number of workers employed 

Total number of Labels Distirbuted 

Office Routine — 

Number of phone calls ver day 
Personal interviews ver day 



56 
49 



60 

1008 

* 13,891.14 

$ 12.640.lt 



332 

165 

15,800 

21,155,000 



36 
41 



January 31, 1935 



Investigations — ■ 



Number previously reported 
Number made during January 
Total 



14C7 
459 



1866 



Number of Non-Compliance Cases pending 62 
Number closed during January 26 



9811 



CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Fifth Avenue 
Fev York 

STATISTICAL . REPORT 
January 31, 1935 



Restitution — : 



Number of Firms 
Number of Individual Employees 
Total Amount Paid 
Approximate amount pending 

Analysis of the Industry — 

Number of Manufacturers 

Number of Contractors 

Approximate number of workers employed 



63 

1,031 
£14,625.84 
$13,480.00 



332 

165 

15,800 



Total number of labels distributed as of Januarv 28 

Office Routine — 

Average number of phone c.^lls ner day 37 
Average number of personal interviews ner day 39 



February 28, 1935 



Investigations — 



Number previously reported 
Number made during February 
Total 

Number of Non-Compliance Cases Pending 
Nunber closed during February 

Restitution — 

Number of Firms 

Number of Individual Employees 
Total Amount Paid 
Approximate amount pending 

Analysis of the Industry — 

Number of Manufacturers 

Number of Contractors 

Approximate TT umber of workers employed 



1,866 
554 



91 
22 



'64 

1,033 

*14, 668.30 

$16,000.00 



337 
175 

15,800 



24,901,000 



2,420 



9811 



-389- 

CODS AUTHORITY 
LADIES' HAKEBAG EJDUSTEY 
347 Fifth Avenue 
Hew York 



STATISTICAL REPORT 



February 28, 1935 



Total number of Labels distributed as of February 28 28,590,500 

Office Routine — 

Average Number of nhone calls ver day 36 

Average TT umber of personal interviews ner day 37 



)811 



-390- 



EXHIBIT S 

Interpretation - Order 332-10 






9811 



-391- 



Name of Code: 



EXHIBIT "S« 
NATIONAL RECOVERY ADMINISTRATION 
INTERPRETATION 
No. 332-10 
Ladies Hand Bag Industry, Approved Code No. 332 
Part: Article V, Section 10 



A - oT)licanti 



Facts: 



QUESTION: 



INTERPRETATION: 



RECOMMENDED: 



Code Authority of the Ladies Hand Bag Industry, 
303 Fifth Avenue, New York, New York 

It is provided in Article V, Section 10, of 
the Code of Fair Competition for the Ladies 
Hand Bag Industry, in part, that 

"No member of the Industry shall give out 
work to be performed in any home or dwell- 
ing place, except that this prohibition 
shall not apply to hand-beading, hand- 
crocheting, or hand-embroider;.''. . . " 

and it appears that certain types of hand 
bags are manufacturered from numerous pieces 
of leather, linked together, by a process of 
interlocking by hand and that said process is 
sometimes known as "hand-crocheting" . 

Is the manufacture of ladies hand bags from 
numerous pieces of leather linked together 
by a process of inter-locking by hand included 
under the term "hand- crocheting" as used in 
said provision of said Code? 

It is ruled that the manufacture of ladies 
hand bags from numerous pieces of leather 
linked together by a process of interlocking 
by hand shall not be included under the term 
"hand-crocheting" , as used in said provision 
of said Codo. 

APPROVED: 



EARL DEAN HOWARD (Signed ') 
Earl Dean Howard 
Deputy Administrator 



SOL A. ROSENBLATT (Signed ) 
Sol A. Rosenblatt 
Division Administrator 
Division No. 5. 



9811 



-392- 



XHIBI_.| T 

Breakdown of Code Authority 



9811 



ilame & 
Connection 



-393- 

EXHI3IT »T» 

Animal 
Factory Kind of Sales 

Location Goods Mfgd. Volume 



S. Mutterperl, Pres. New Bed- ..$1.00 
Sol, Mutterperl, Inc. ford, Mass. 
330 Fifth Ave., H. Y. C. 

G. Meyers, Pres. So. Hprwalk, 1.00 

Meyers Mfg. Co., Inc. Conn. 
3X Fifth Ave., II. Y. C. 

*M. White, Pros. Scranton, Pa.l..00* 

Stylocraft Leather 

Goods Co. 
5C1 Seventh Ave., 11. Y. 

H. Schoenfeld, Pres. 

Schoenfold & Wolf, Inc. Trenton, N. J. 

14 3ast 33 St., N. Y. C. 



1.00 & 3.00 25Q.C00 



Employees: 
number of 



650,000 330 



900,000 450 



750,000 246 



32 



W. Kadin, Treasurer 
Kadin Brothers Inc. 
132 West 36 St., IT. Y. C 



Hudson, IT. Y. 1.00 & 3.00 900,000 100 



M. H. Blurenfeld, Pres. Chicago, 111. 1.00 & 3.00 200,000 
Mir.o Leather Goods Co. 

Inc. 
402 So. Market St. Chicago 



78 



S. R. Goldsmith, Pres. Allentown, 
Goldsmith Bros. Mfg. Co. Inc. Pa. 
38 West 32 St. N.Y.C. 



3.00 to 5. 00 600,000 400 



•J.Michel, Pres. Clinton, Mass. 3.00 & 5.C0* 1,000,000 325 
Michel, Maksik & Feldrnan, 

Inc. 
159 Madison Ave. H. Y. C. 



I. Schoenholz, Pres. Hew York 

Schoenholz & Weeks, Inc. 
15 East 32 St., H. Y. C. 



5.00 & Upwards 75,000 25 



R. Koret, Pres. 

Koret, Inc. 

33 East 33 St., H. Y. C. 



Hew York 



;".'. Iranernan, Pres. 1'ew York 

Bagcraft L'fg. Inc. 

.30 East 33 St., i*. "-". C 

M. Magid, Pres. Hew York 

A. I . Magid Company 

14 East 33 St., H. Y. C. 



5.00 & Upwards 450, 000 250 



5.00 , f ' : Upwards 150,000 50 



Bead Bags 



250,000 27 



9811 



-394- 

Annual 
Factory Kind of Sales . Employees: 
Name & Connection Location Goods Mfgd . Volume i?umber of 

*A. Greenbaum, Treas. Bethlehem, Pa. Fabric Bags 800,000 132 

Chic Bag Co. , Inc. 

6 East 32 St., N. Y. C. 

♦Appointed "by Administration Member "but approval not given "until a few 
days before the close so that these men did not sit upon the Board. 

The following is a general breakdown of the industry on dollar volume 
basis: 

Bags selling up to $1.00 at retail . 30>j 
Bags selling from $1.00 to $3.00 at retail 40, j 
Bags selling from $3.00 to $5.00 at retail 20,j 
Bags selling from $5.00 and upwards at retail 10,j 
Beaded Bags 7;i> of above total percentage 
Fabric Bags 15-i of above total percentage 



9811 



9811 



-395- 



IHIBI'T U 
Paul Abel son's Report 



-395- 



EXEI3IT »U« 



April 13, 1934 



Dr. Paul A"belson 
Special Millinery 3oard 
8" West 37th Street 
New York, N. Y. 



Dear Dr. Abelson: 



Your appointment as Administration Member to the Handbag 
Code Authority is now going through. I will write Mr. Mitten- 
thai to that effect. 

I am very anxious that that Code Authority send me at 
the earliest possible moment the definition they -vro'iose for 
the semi-skilled workers. 

I have just suggested to the Director of the Men's Garter, 
Suspender and Belt Code Authority that ho confer with you con- 
cerning impending labor difficulties of certain of his members. 
He came to me for advice and I happened to think that here was a 
little situation that might interest you. The gentleman's name is 
Mr. Kendrick who is well known to us and for whom we have a very 
high regard. 



Yours very sincerely 



Barle Dean Howard 
Deputy Administrator 



edh/g 



9311 



-397- 

UATIOHAL EECOVUHY ADIvIIPISTHATIOH 

Special Millinery Board 

Under Executive Order of December 15, 1933 

3 West 37th Street 

NSW YOHK CITY 

April 18th, 1934 

Dr. 3arl Dean Howard, 

Deputy Administrator 

National Recovery Administration, 

Washington, D. C. 

Dear Dr. Howard: - 

I have your letter of the 17th inst. concerning the Hand Bag 
Code. 

My information is that the meeting of the Code Authority 
scheduled for April 19th, 1934 has been postponed because of the 
absence of the Chairman of the Code Authority from the City. 

In the meantime, Mr. Pearson who had told me about the meet- 
ing on Thursday, had arranged for a meeting between him, myself 
and a group of protesting manufacturers, some who are on the Code 
Authority and some out. They speak for the national Association 
of Ladies' Hand Bag Manufacturers. We spent several hours with them. 

Aside from the petty jealousies and desires for paying jobs 
on the Code Authority, I gather that there is a basic conflict be- 
tween these out of town manufacturers and the Hew York people. 

I have of course expressed no opinion but simply suggested 
that an effort be made to have harmony within the Trade before 
these people run to Washington and try to block the work of the 
Code Authority as it is at present constituted. 

However, this need for harmony within the Code Authority 
ought not to interfere with the formulation of a definition of 
the term 'semi skilled employee'. 

If you have not written to Mr. Mittenthal, perhaps it would 
be well for you to write him as you did in the case of the Infants' 
Wear so that they may know of the Administration's decision to have 
me the Administrative member on that Code. I shall communicate 
with Mr. Mittenthal, nevertheless, as you suggest. 

May I suggest that if writing to me on matters other than 
Special Millinery Board that you address letters to my office, 
#11 West 42nd Street, Hew Y rk City. I am not always at the Special 
Millinery Board in the morning so that important communications from 
you might be delayed if you continue to address them to me at #8 West 
37th Street, Hew York City. 

Very sincerely yours, 
PA:ge /s/ PAUL A3ELS0N 

9811 



-398- 



SXII3 IT V 

Code Authority Heport - Virginia Art 



9811 



-399- 
EXHIBIT V 

August 31, 1934. 



Mr. Leigh H. Ore 
Assistant Deputy Administrator 
Commerce Building 
Washington, D. C. 

Dear Mr. Ore: 

The Virginia Art Goods Studios, Inc. presented a petition for an amend- 
ment to the Code of Fair Competition for the Ladies' Handbag Industry "by 
adding to Article IV of the Code, the following section: 

(a) In the States of Virginia, North Carolina, South Carolina, 
Georgia, Florida, Mississippi, Louisiana, Alabama, Tennessee 
and Texas, the minimum wage for unskilled employees shell be 
30^ per hour. 

(b) The minimum wage for semi-skilled employees shall be 3?§^ per 
hour. 

(c) Le.rners may be employed for a period of not exceeding ten 
weeks at a minimum wage of 24^ per hour, provided that the 
nuuber of such learners shall not at any time exceed 15 per 
cent of the entire number of employees. 

The petition was supported by the following documents: 

(a) Copy of letter, dated March 30, 1934, from Robert D. Ramsey, 
Business Manager of the Chamber of Commerce of Lynchburg, to 
James C. Worthy, Assistant Deputy Administrator, National 
Recovery Administration. 

(b) Affidavit of Mamie E. Rohr, President of Virginia Art Goods 
Studious, Inc. 

(c) Affidavit of Edmund Waltuck. 

(d) Affidavit of 0. H. Tufts. 

The Virginia Art Goods Studies, Inc. states that a copy of its petition 
was also sent to Col. H. S. Berry, Deputy Administrator. 

After careful consideration of the statements made and the evidence 
presented in these documents, the Code Authority, at a meeting held 
August 30, 1934 at the Hotel McAlpin, voted to deny the petition of 
the Virginia Art Goods Studios, for an amendment to the Code in which 
they request: 



9811 



-400- 

(a) to be granted a differential in wage rates in 
favor of the southern territories. 

("b) to fix a minimum wr.ge for semi-skilled workers at 
37-vr^ per liour. 

(c) to permit learners for a period of ten weeks at a 

minimum wage of 24^ per hour, not to exceed 15 percent 
of the entire number of employees. 

The Virginia Art Goods Studios, Inc. in support of their petition 
claim that the manufacturers cf Ladies' handbags in the northern rotates 
have skilled labor who work witn a "speed which can be equalled only 
by equally skilled experienced labor". 

Fifty percent of the handbag industry is located outside the metro- 
politan area of hew York in which ho experienced help is available, 
and the manufacturers obtain their workers in the same manner as does 
the Virginia Art Goods Studios, Inc. In the metropolitan area of New 
York, in which experienced help is available, the wages paid such 
help is from two to three times more than paid the inexperienced help. 

The Virginia Art Goods Studios, Inc. claim that they are pioneers in 
their locality. 

The records show this firm has been established over eight years, and 
that during the past five years, they have enjoyed a large volume of 
business in the industry, employing at times as many as 168 workers. 
These workers have all had some training by this time, and p,re avail- 
able mostly at the minimum w. ge rate. The question whether the labor 
in Lynchburg, Virginia, can compare with northern v/orkers in volume 
in speed of production is not determinable, since the kind and quality 
of work varies in each factory, and lack of production frequently the 
result of inefficiency in factory managements as has been disclosed 
through investigation made in other industries in which similar 
claims have been made. 

The statement of the Virginia Art Goods Studios, Inc. that "the prac- 
tical o:nd inevitable result is that the Virginia Art Goods Studios, 
Inc. cannot successfully compete with other manufacturers whose cut- 
put per capita of employees is so much greater" — this merely expresses 
their opinion. 

The loss sustained by -the Virginia Art Goods Studios, Inc. during the 
year 1933 may have been due to a dozen or mere causes, and to have 
this Company claim that such losses resulted from increased labor costs, 
is merely expressing a convenient conclusion. Any increr.se in labor 
costs might have been included in the cost of their product, or they 
may have offset this increase by taking the difference out of the 
value of materials, if they fail to do so, they cannot justly attribute 
it to increased labor costs. 



9811 



-401- 

From the figures furnished by the Company of their sales and sales 
costs, it would appear that the?/ are pricing their goods without a 
safe and adequate profit. 

The test of efficiency in workers made by their production manager, 
is not based on facts, it is merely expressing his individual opinion. 

The statement that the products of tie Ccmpany are sold at a higher 
price than the products of northern factories is not sustained, par- 
ticularly since this Company manufactures a unique line of handbags, 
different from the bags manuf actured by ether firms in the industry, 
and further they are protected by patents which they have attested to. 

The Virginia Art Goods Studios, Inc. do a good volume of business and 
they are rated financially as one of the outstanding firms in the in- 
dustry. 

It is not necessary for the Virginia Art Goods Studios, Inc. to ob- 
tain lower wage rates in order to compete with factories in the northern 
territory, and the fact that they have suffered a small loss during 
the year 1S33 is due to the same reasons that caused other factories 
in the industry to suffer larger losses, all due to the fact that they 
are trying to give too great values at the prices. 



The request to amend the Code 

skilled workers carmot be cons 

a semi-skilled worker in the Code. 



to allow a wage rate of Zl\h for semi- 
idered since there is no definition of 



The request to amend the Code to permit learners is denied by the Code 
Authority at tie present time, end until the Code shall be amended by 
agreement with the Administrator to provide learners for tie entire 
industry. 

The Virginia Art Goods Studios, Inc. has been operating under a stay 
since the effective date of the Code, March 26, 1934. This stay ex- 
pires September 1, 1934. The Code Authority protests against the con- 
tinuance of this stay beyond September 1, 1S34, since the Virginia 
Art Goods Studios, Inc. had the entire month of August during which 
tiey might have submitted their petition, however, they failed to 
do so until August 27, 1934, and they are novr requesting that the 
exemption period should be extended to such date as tie anticipated 
hearing shall have been held, and the proposed amendments disposed of. 

Very truly yours, 

CODS AUTHCEITY 
LADIES' HANDBAG HIDU3THY 



Aa:AS 



A. iiit ten thai 



9811 



-402- 



EXHISIT W 

Erief, answer to the same; correspondence 
on the Meeker Comoany 



9811 



-403- 
EXHIBIT »' " 

THE MT^JCEH COMPANY, INC. 
Pine Leather Goods 

JOPLIN, MISSOURI 

Conditions affecting the aIEEKSR COMPANY'S operations under tne 
LADIES HANDBAG INDUSTRY COD?: No. 332, adopted wiarch 14th, 1934. 



The following are some of the handicaps under which the Meeker 
Company, Joplin, Missouri, are operating, due to their isolated position 
in this field of manufacturing. None of tnese handicaps were given any 
consideration in tne formation of tne Code, whicn after several months 
of neerings and controversies vas adopted and put into effect in March, 
193<±. 

All of these handic.-ps wore Celled to the attention of the eastern 
manufacturers formulating the Code and the MMA authorities in "7ashington, 
but no consideration was given, and our subsequent protests \7ere in nearly 
all cases not even answered. 

Joplin, Missouri, is located 1-iOO miles from New York City. Prac- 
tical^ ell ladies' handbags ...re m" nuf yet ured by concerns in New York City 
and that immediate vicinity, '.here there are several nundred manufacturers, 
large and snail. 

Nearly 100 o of the materials used in fabricating ladies' handbags, 
consisting of leathei , :aetal frames, silks, mirrors, paper,, wadding, but- 
tons, backing cloth, cen-nt, -zippers, and a. few other items, are purchased 
in New York City and in the New England States. 

The Meeker Company, in purchasing sich -materials, is handicapped 
in competition with the New York manufacturers, in that heavy freight, 
express and parcel oost charges nave to be paid; cnarges that the New 
York manufacturer does not nave to bear*. 'These charges, in addition to 
traveling expenses going to narket, telegraph and othe:: expenses, amounted 
to 2. 2, o of our gross sales for the year 1934, and expense the New York 
racUiuf acturer does not have. ITev; York, being a style center, it is neces- 
sary that the Meeker Company send representatives to New York City and 
vicinity frequently during tne year to buy materials ond contact for new 
styles, observe style cnanges and ascertain style trends, the nandbag 
business being a rapidly changing style proposition. 

The eastern manufacturers located in New York City and vicinity, 
vhere there are many factories, have an abundance of skilled labor to 
draw from. Here in JODlin, Missouri, there are no other handbag manu- 
facturers, making our labor situation very difficult, as there are peak 
seasons of manuf acturing at which time, in the absence of trained help, 
we are compelled to employ learners who know nothing whatever of our line 
of work and who in most cases have had no factory experience of any kind 
whet ever. 

9811 






-404- 

'■'e have appealed to the NBA Administrators in Washington and 
to the Code Authority for the ladies' handbag Code, located in New York, 
for the privilege of employing learners at less then the minimum wage 
the Code carries, "out have in every esse "been turned down or our pleas 
entirely ignored, although the Code that is now in effect provides that 
the Administrator may, if ne sees fit, provide for the employment of 
learners at less than the minimum wage for a short period. 

The Code Authority, being located in "Jew York City, composed of a 
New York personnel, it is evident that they consider the handbag manufac- 
turing business from u, metropolitan, eastern, or ": T ew York standpoint only, 
and are not inclined to give any consideration to our isolated position 
in the industry; yet we pay Code dues regularly and abide by it in every 
way, getting nothing out of it except this ado.ed expense and detrinental 
effects. 

le have no -.'age differential to -■ hich we think we are justly en- 
titled, and which was provided for in the original draft of the handbag 
Code, but which provision was left out, we found, when the handbag Code 
finally :rs announced as being in effect. As mentioned, there is a learn- 
ers provision in the Code, but the Administrator has never seen fit to 
give us any relief under it. The net results to us under the Code have 
been that we are compelled to pey the same minimum wage for inexperienced 
help, without even a short period in which to teach them to do our kind 
of work, that the Hew York manufacturer is compelled to pay for experienced 
help. The handicap to us can be readily seen. 

The ueeker Company's factory payroll for IS 34 was £125,806.00, 
which is 30.1.o of our volume of sales for the year, 'hich is a 19, o in- 
crease over 193 ; . Our year's operation for 1934 showing a net loss. 
As a. result of these handicaps, we have been forced to discontinue making 
certain competitive lines, lines that the eastern manufacture.es ap- 
parently are making successfully. Our business so far this year being 
33-l/3,a less in volume than 1934. Naturally we are employing less people 
at the present time than we were employing last year and would employ 
under fair competitive conditions. As an example, last year at this time 
we were employing 176 people,- while at present we are employing 42. 

Another handicap to which consideration should be given is on 
account of our long distance from material market we are compelled to 
carry heavy inventories that the eastern manufacturers do not have to 
carry. 

nelative to a wage differential which we feel we are justly en- 
titled to under the circumstances as enumerated, it should be borne in 
mind that the cost of living in Joplin, Llissouri, is much less than the 
cost of living in the eastern and metropolitan centers. If we were con- 
ceded the differential .hich our handicapped position in this field of 
manufacture plainly indicates we are entitled to, we would be in o. posi- 
tion to employ more labor than we ere able to employ at present, as we 
could again resume lines we have had to discontinue, thus being more of 
a benefit to oar community and be on a better basis as a firm. 



9811 



* 



-405- 

The keeker Company has been in business more than twsnty-f ive 
years, and has never been located aurhere except here in Joplin. Our 
products are sold to department stores and other retail outlets through- 
out the entire United States. 

Another handicap of some import; nee is that in selling our product 
in some of the big eastern cities, particularly hew York City, to make 
such seles ve are compelled to pay the transportation charges to the cus- 
tomer to equalize the transportation cost with that of. the manufacturers 
in New York close to tiie custom. -r where no transportat ipn charges are in- 
volved. 

Another angle to our situation is that while we are the only hand- 
bag manufacturer in out town, or for that matter, in this entire section, 

- in fact, the largest handbag manufacturer 'Test of the Mississippi River, 

- tnere are in our city, garment manufacturers and other manufacturers in 
other toi'ns in our immediate vicinity. Also, tnere are a nufber of shoe 
manufacturers not in our city, but in our vicinity, none of whom are com- 
pelled to pay, the high minimum rate of oay which we have, and all other 
lines of such manuf acturer have a learners provision in their Code, whereby 
they can employ green help for a. certain length of time at 80,o of the min- 
imum wage until they le, rn, at least in a measure, how to perform the work 
they are doing in a satisfactory volume. Of course, in these other lines 
where there are a lot of shoe factories in tae st te, a lot of garment 
manuf; cturers in the state, the/ had sufficient representation when their 
codes were formulated to e::ert an influence so as to enable them to get 
fair consideration. 7e have had no one to cooperate with us in our line 

of manufacture. Therefore, the Code was formulated and put into effect 
and is being operated today solely from the viewpoint of the eastern or 
New York manufacturers, and no consideration given to our concern. 

"7e cannot maintain a representative in Washington to attend all the 
hearings anu make ef.ort to get conditions or rulings that we are justly 
entitled to. Therefore, our condition must be relieved or else we will 
be compelled to pass out of this line of manufacture, as much as we would 
regret to do so. If we are forced from this field, of manufacturing, it 
would mean the loss of employment for around 200 people, leaving our town 
without a payroll which is much needed, and many heads of families without 
employment ,. nd us with a lot of equipment for which v. : e will have no use. 
Out progress in this field will have been made in vain. 

In general, the Code we are operating under now, that is function- 
ing against the interest of our business, is forcing us out of lines of 
manufacturing; and if continued, ".ill in all srobability force us entirely 
out of the handbag business; and to which we are compelled to pay Code 
fees that last year amounted to more than yl, 000, 000, a year during which, 
on account of the restriction under which we are compelled to operate, the 
heavy taxes of one kind or another that we have to pay, causec us to do a 
year's business not at a. profit, but at a heav;r net loss for the yea.r's 
operations, a loss we cannot continue to aear. 



TES iiS'jm COMPANY, INC. 
9811 



-405- 



C THE i/EEICH COuPAMY, IilOi 
o Joplin, Hiss our i 

p 
.7 March 8, 1935 

Mr. Howell Cheney 
Industrial Advisory Board 
National Kecovery Administration 
Washington, D. C. 

Dec,r Sir: 

With reference to your recent communications relative to our 
position in the handbag industry and our contention that we should have 
a wage differential, and that we should be permitted to employ learners 
at less than the minimum wage. 

We want you to know that we full"'- appreciate the interest you 

are taking in our case. It is the first real interest that has ever been 

shown by anyone connected with the Administration, with none shown by the 
Code Authority. 

We particul-rly appreciate the advice in your letter of February 
19th that we endeavor to interest different agencies you mention in tes- 
tifying as to the conditions we are operating under in order to show that 
we are really entitled to what we are contending for. 

The Code as it now s tanas provides for learners if the Adminis- 
trator sees fit to grant such. We have been unable to get the Code Au- 
thoritjr or any of the Washington authorities that have heretofore been 
watching this Code to give us such permission; all of them probably feel- 
ing that if they '-;ere to grant us the privilege of working learners at 
less than the minimum wage, they 'ould probablj' have to do it for other 
manufacturers. Others may be entitled to such provisions the same as we 
are. 

We realize there is a surplus of experienced labor in the East, 
but there is no such surplus here in our town; nobody employing labor of 
our kind except ourselves. There are no other concerns of our kind in 
this part of the entire country. 

As for the differential that we think we are justly entitled 
to, when the public hearing on the Code was held in December 1933 in 
Wo.shington, which was the only meeting we have attended, no objection to 
a differential was voiced by the New York oeo"ole. 

A letter addressed to the writer by Mr. A. Liittenthal, who now 
heads the Handbag Code, is enclosed. This will show you the attitude 
that then prevailed as to our contention for a differential, and apparently 
the reason it was not incorporated in the Code when it was finally adopted. 



9811 



-407- 



If you 'ill be good enough to return this letter it will he appreciated. 
The explanation and sentiment of Lir. iiittenthal as outlined in this let- 
ter might he detrimental to him "'ere the contents of this letter gener- 
ally known. 

If the "Jew York manufacturers '"/ere inclined to be fair-minded 
toward us as a competitor, the;/ should give consideration to our position 
in this field of manufacture, SatuTally we do not know what their cost 
of manufacturing is. Our cost was a little more than 30,0 of our sales 
last year. 

As "-e have time and again advised the Code Authority and the 
ISA officii Is whenever we had the opportunity, that practically all of 
our supplies are bought in New York City and that immediate vicinity, 
necessitating heavy transportation en. rges that the Hew York manufacturer 
does not have to bear. Also it takes time to get our materials, and re- 
quires that we carry heavier inventories, all of which should be given 
consideration to if it is intended that we should be on a fair competitive 
basis. 

As for the various factors entering into the labor turnover, 
our situation is different from the 'Tex York manufacturers in that they 
have experienced help that is idle, willing to be employed, that they can 
secure. TTitlT'us on account of the seasonal variations, it is impossible 
for us to at all times maintain our factory force with experienced help, 
and our contention is that when we are compelled to employ learners we 
should not have to pay them the minimum '.rage that the New York manufac- 
turer can get skilled help for, until they acquire some degree of skill. 

T7e have little hopes of obt ining any relief thru the Code 
Authority. They are Hew York men thoroughly familiar with New York con- 
ditions, interested only in New York conditions and not familiar with our 
situation, -^pprrently they are afraid if they make rulings to put us on 
a fair competitive bjsis it '.ill disrupt the situation in the East, which 
might or might not be true. Ho v; ever, it is our own ousiness that we are 
trying to carrv on ana unless the feeling that we should not be manufac- 
turing handbags here in Missouri exists, they should be willing to be 
fair and give just consideration to our position. 

T7e have already been forced out of certain lines for which 
there is a demand that the 3ast is supplying. Our business so far this 
year is approximately 33 1/3 3 off from last year. 

Relative to equipment, we nave every contrivance that we 
know of to reduce the cost ox oroduction. ^"e have United Shoe Machinery 
Company's machines in our place wherever we can find an economical place 
for them. We feel that we know how to run our business and we are as 
alert as any of them when it comes to manufacturing processes. 



9311 



-408- 



We would have no cause to complain relative to the Code if we 
had a wage differential to which we know wo are entitled, and if we 
could get author it/ to employ learners at less than the minimum wage for 
a time until they ccn get familiar with our work and he able to e c rn the 
minimum or more. We are not asking that the Code be abolished unless we 
cannot ger relief. Tie only want fair treatment under it. 

We shall endeavor to follow your advice as to the agencies we 
may be able to interest in explaining our situation and confirming our 
contentions. We would be very glad to have a government investigator 
come to Joplin and go over the '.hole situation, in fact, it is just what 
we would like. The government has seen fit to allow differentials in 
nearly every other line of industry, realizing no doubt the necessity for 
the same. There isn't another industry in our part of the country that 
has the high minimum wage that we have, and in nearby towns there are 
shoe factories, shirt and garment factories and in oiir own town cigar fac- 
tories. 

In connection with the whole matter, we fear we are not pre- 
senting the situation in as orderly a manner as you wish, or as the 23EA 
authorities would like to have it presented. Should there be any ques- 
tions of any nature yoti would like to ask, or any statements 3'ou would 
like to have us make, we will welcome the opportunity of answering or 
making the seme. 

We don't want to discontinue this line of manufacturing; we 
would have little business left and would have to throw a lot of people, 
nearly all of them with families depending upon them, out of employment. 

Your further comments or advice on the situation will be ap- 
preciated very much. 

Yours very truly, 

THE UliEEEH COi.iP.AilY, INC. 

(Signed) C. Meeker 
President 



Ci/i/C 



9811 



-409- 



Llarch 11, 1935 

Mr. C. Meeker, President 
The Meeker Company, Inc. 
Joplin, Missouri 

Dear Sir; 

I am in receipt of your letter of March 3th which must 
have crossed mine of recent date. I note the letter from the 
present Code Authority to you, which I return herewith. This does 
give an illuminating view both of the vicissitudes through which 
the Code has passed and of the attitude of the Code Authority toward 
your peculiar problem. 

The letter which I have already written you will have 
covered the subject of an application to the Administrator for the 
setting up of learner provisions. This can be duly filed with the 
supporting evidence which I have suggested to you. I am sure that 
the matter will receive most cardful consideration. What the re- 
sults will be, I cannot predict because just at the present time the 
continuance of all codes is under serious doubt. 

In regard to the establishing of differentials between 
Missouri and the East, it would be necessary for you to present the 
following evidence, backed by affidavits of responsible parties other 
than yourself: 

1. wages now being paid in your region for similar 
classes of work; 

2. wages paid by your industry; per cent of labor 
costs to total costs in Missouri, as compared with 
similar figures for the Eastern territory. 

3. Expenses other than labor costs in your region 
in excess of Eastern expenses. 

I have asked the Research and Planning Division to accu- 
mulate some figures in regard to the per cent of labor costs to the 
total costs in the Eastern Division and hope they will be able to 
secure this information. The remainder of the information you would 
have to secure so that it could be presented in brief form, supported 
by the necessary affidavits. 

As you point out, the application for learner provisions 
are within the powers of the administrator to grant. Application for 
the setting up of differentials, I am afraid, would require an amend- 
ment of the Code tnd this would nave to go, in the first instance, 
through the Code Authority. If, however, you were blocked there, you 
could take the matter up with the Administrator. I would, however, on 
the whole, advise you to wait until Congress has expressed itself more 
definitely as to the future of all Codes, as it may be unnecessary to 
suggest further amendments at the present time. 

ENG. Y0urs truly ' 

Howell Cheney 

9811 ■■;• . :: —,:,-,- 



-410- 



C0D3 AUTHORITY 
LADIES' EAND3AG IHD0ST2Y 
34? IUTB AVEHU1 
C HE" YORK 


P 
Y April 26, 1935 



Mr. 0. W. Pearson 

Artificial Flower & Feather Industry 

8 TTest 37 Street 

He 1 ;; York City 

Dear Mr. Pearson: 

The Meeker Co. hs,s petitioned the Adminis- 
tration for permission to employ learners at less than 
the Code "ages. A copy of their request is attached 
hereto. 

".'ill you kindly indicate on this notice, 
whether you approve or disapprove granting the request 
of the meeker Co. , and return to the office of the Code 
Authority. 

Very truly yours, 

CODS AUTHORITY 
LADIES' HAHD3AG INDUSTRY 

AM: AS 
enc. 



A. Mittenthal 
Code Director 

I APPROVE the petition of the Meeker Co. to employ learners 
at less than the Code wages. 

( Signed) , 



I DISAPPROVE the petition of the Meeker Go. to employ learners 
at less than the Code wages. 

(.Signed) 



5811 



-411- 

CODE AUTHOHITY 
LADIES' HANDBAG INDUSTEY 

C 347 EIFTH AVE9U1 

US" YOBK 

? 
Y April 26, 1935 

Col. Walter Mangum 
Deputy Administrator 
Comuerce Building 
Washington, D. G. 

Lear Col. M angura : 

The Code Authority has denied the petition of the Meeker Co. , 
Joplin, Missouri for permission to eraploy learners at less than 
the Code wages, for the following reasons: 

"Joplin, Missouri is located 1400 miles from New York City. 
Practically all ladies' handbags are manufactured "by concerns 
in New York City _nd that immediate vicinity, where there are 
several hundred manufacturers, large and small." 

We"cannot agree that any manufacturer is handicapped 
by being located 1400 miles from New York City. New 
York City is not the geographical center of the United 
States, and neither is it the distributing center for 
the handbag industry in the United States. Joplin, 
Missouri is more centrally located for distribution 
then are factories located in Hew York City. It is 
true that the Meeker Co. mcy find that they are at a 
disadvantage for distribution in the New England or 
Middle Atlantic States, but they enjoy :n equal advan- 
tage in the Middle TTest, Southwest, Northwest and Pacific 
Coast territories. The Meeker Co. employ mere than 18 
traveling salesmen who concentrate on this territory. 

"Nearly 100/ of the materials used in fabricating ladies' hand- 
bags, consisting of leather, metal frames, silks, mirrors, paper, 
wadding, buttons, backing, cloth, cement, zippers, and a few 
other items, are purchased in New York City and in the New England 
States. The Meeker Co. in purchasing such materials, is handi- 
capped in competition with the New York manufacturers, in that 
heavy freight, express and parcel post charges have to be paid; 
charges that the New York manufacturer does not have to bear. 
These charges, in addition to traveling expenses going to market, 
telegraph and other expenses, amounted to 2.2,o of our gross sales 
for the year 1934, an expense the New York manufacturer does not 
have. Nov/ York being a style center, it is necessary thai, the 



J811 



-412- 



Meeker Co. send representatives to New York City and vicinity 
frequently daring the year to buy materials and contact for 
new styles, observe style changes and ascertain style trends, 
the handbag business being a rapidly changing style proposition." 

Their claim that one hundred per cent of the materials 
used for fabricating ladies' handbags are purchased in 
New York City and the New England States is not absolutely 
accurate. A great deal of the leather they use is pur- 
chased from factories located in Milwaukee, TTisconsin and 
G-irard, Ohio. This applies particularly jbo calf leather 
trnd steer hides. The fact that they have to pay freight 
and express charges on raw materials shipped from eastern 
points and that their traveling expenses to the New York 
market amount in tot. 1 to 2. 2$ does not prove that this 
percentage represents a disadvantage. Eastern manufac- 
turers also have to pay transportation charges on many 
of their raw materials. We have not sufficient data to 
show the percentage that this item bears to their total 
cost. Whatever disadvantage there may be in payment of 
transportation charges to Joplin, Missouri, on raw ma- 
terials, it is fully offset by the advantage the Meeker Co. 
has in being able to deliver their finished product at 
lower transportation charges to concerns located in adja- 
cent territories. The Meeker Co. includes in this amount, 
the expense of coming to New York to contact new styles, 
observe style changes and eastern style trends. The New 
York manufacturers go to Paris for the sane purposes and 
copy styles for the Meeker Co. to copy. 

"The eastern manufacturers located in New York City and vicinity, 
where there are many factories, have an abundance of skilled labor 
to draw from. Here in Joplin, Missouri, there are no other handbag 
manufacturers, making our labor situation very difficult, a.s there 
are peak seasons of manufacturing at which time, in the absence of 
trained help, we are compelled to employ learners who know nothing 
whatever of our line of work a. id who in most cases have had no 
factory experience of any kind whatever." 

The skilled labor is confined almost entirely to New York 
City where only 25 /o of the industry is now located. All 
factories outside of New York had.no skilled labor to 
start with, and were compelled to break in new help who 
never worked in the industry, in cities much smaller than 
Joplin, Mo. The only advantage that they had over the 
factories located in New York City was the fact that they 
could employ their workers at the minimum wage of $14 a 
week, whereas the manufacturers in New York City have a 
highly organized Union with classification of workers, and 
minimum wage scales, for most branches, of $37.50 for 37): 
hours of work; whereas factories outside of New York City, 
including the Meeker Co. work 40 hours a week. 



9811 



-413- 



Pactories now locating in the eastern cities are 
mostly in localities where there has never "been a 
handbag factory, and where evevj worker is recruited 
from other industries, not "even kindred. These manu- 
facturers equip their factories with every modern ma- 
chine that has been introduced in the industry during 
the past five years, and as a result, a great many of 
the operations formerly performed by skilled workers 
is now performed by new workers working on a machine. 

The Meeker Co. , has been in business in Joplin, Mo. 
for over '25 years. At one tine, they had one of the 
lc rgest businesses in the industry, and employed over 
400 people. At the present time, they employ on the 
average of 156 people in their handbag department, (see 
exhibit taken from the records) which is proof that 
the Meeker Co, has built up a reserve supply of labor 
who they can call upon whenever necessary, since there 
are no competing factories in Joplin or vicinity. It 
is more than likely that these workers are available to 
them at all times. 

"We have appealed to the ICJA Administrators in Washington and to 
the Code Authority for the Ladies' Handbag Code, located in New 
York, for the privilege of employing learne::s at less than the 
minimum wage the Code carries, but have in every case been turned 
down or our pleas entirely ignored, although the Code that is now 
in effect provides that the Administrator may, if he sees fit, pro- 
vide for the employment of learners at less than the minimum wage 
for a short period." 

The Meeker Co. complained that their appeals to the Code 
Authority for permission to employ learners at less than 
the minimum wage has been turned down. The fact is, their 
applications were accorded the same consideration that were 
given to similar requests for learners by other members of 
the industry; in some cases these applications came from 
new factories located in towns where no handbag factory has 
ever existed, and they were not permitted to employ learners 
at less than the minimum wage. The reqaest of the Meeker Co. 
for an exception from the minimum wage rate may not be in- 
tended for learners, but would be made to apply to former 
workers whom they seek to reemploy. 

"The Code Authority being located in New York City, composed of a 
Hew York personnel, it is evident that they consider the handbag 
manufacturing business from a metropolitan, eastern, or New York 
standpoint only, and are not inclined to give any consideration to 
our isolated position in the industry; jet we pay Code dues regu- 
larly and abide by it in ever;.- way, getting nothing out of it ex- 
cept this added expense and detrimental effects." 



9811 



-41 v- 

The Code Authority is not compose:; ox iaim.fi cturers 
with plants loc....te^ in Hew York City ,:lone. The present 
membership of the 3ode Authority is ten, and the plants 
they represent are as follows: 

Bagcruft ufg. Inc. Hew York City 
Goldsmith 3ros. Llfg. Co.. . .illontown, Pa. 

Kadin Bros. Hudson, H« Y. 

Koret, Inc. He 1 ;/ York City 

A. I. Liagid Co. Jew York City 

iieyers Mfg. Co. So., Horwalk, Conn. 
i.Iirro Leather Goods Co. , Chicago, 111. 

Sol Liutterperl, Inc. Hew Bedford, Mass. 

Schoenfeld & Wolf , Inc. Trento.n, H. J. 

Schoehhol~ Se Y. r eeks, Inc. He// York City 

Some of these manufacturers moved their plants to alaces 
outside of Hew York City recruiting their workers from the 
unemployed in tneir loci communities. Some factories en- 
gaging 200 or more workers have SO, a of the total new workers 
without previous experience, but in no case were they per- 
mitted to pay less than the minimum to such beginners. 

The Liid/cst territory have one representative on the Code 
Authority out of a total of ten members and they produce 
about ten per cent of the total production of the industry. 

"We have no wage differential to ./hich we think we are justly en- 
titled, - nd '/hich was oroviued for in the original draft of the 
handbag Code, but which provision was left. out, we found, -hen the 
handbag Code finally '.'as announced as being in effect. As men- 
tioned, there is a learners' provision in the Code, but the Ad- 
ministrator has never seen fir to give us any relief under it. 
The net results to- lis under the Code have been that we are com- 
pelled to pay the seme minimum wage for inexperienced help, with- 
out even a short period in "/hich to teach them to do our kind of 
work, that the Hew York manufacturer is compelled to pa/ for ex- 
perienced help. The handicap to us can be readily seen." 

The Lieeker Co. should, consider that if the provisions in 
the Code relating to learners was made effective for them, 
it would also apply to ever r other member in the industry, 
with the effect of equalising a wage less than the minimum 
throughout the industry, •/hich is the very opposite of what 
HSA is attempting to accomplish. The Code has destroyed 
competition based solely on the lowest labor costs, and as 
a result, it has given legitimate and honest manufacturers 
like the heeker Co. an opportunity to compete on style, ser- 
vice and materials. 



J811 



-415- 

"The l.ieeker Company's factory payroll for 1934 was $125,806.00, 
which is 30.1jo of o\ir volume of sales for the year, which is a 
19$ increase over 1933. Our year's operation for 1934 showing a 
net loss. As a result of these handicaps, we have "been forced 
to discontinue making certain competitive lines, lines that the 
eastern manufacturers apparently are making successfully. Our 
business so far this year being 33-1/3$ less in volume than 1934. 
Naturally we are employing less people at the present time than 
we were employing last year and would employ under fair competi- 
tive conditions.. As an example, last year at this time we were 
employing 176 people, while at present we are employing 42." 

The Meeker Company's payroll for 1934 shows an increase 
of only 19,i over 1933, which was the lowest wage level 
in the history of the industry. We consider 19$ a very 
low increase. If the factory payroll is 20$ of the sales 
volume, 19$: increase in the factory payroll is only an in- 
crease of 5.7$ based on the sales volume. At this rate, 
a hag of equal value, selling for $3 wholesale in 1933, 
would have to he sold for $3.17 in 1934, which is not an 
exorbitant increase, and this increase might easily- he 
absorbed by reducing other items of cost, which will per- 
mit the manufacturer to maintain the original $3 price. 
A --handbag is made up of at least 20 different mat erials 
and requires at least 50 labor operations. 

The Meeker Company claims they employed 176 workers last 
year, and employ only 42 workers now. At the same time, 
they claim their volume of sales only fell off 33 1/3$, 
yet they are producing this volume, with only 24^$ of 
their workers. According to this statement, their percent- 
age of labor costs is less with 42 workers, than it was 
with 176 workers. The Spring season of 1934 was very bad 
throughout ' the industry, most of the factories reported 
33 l/3$ to 50$ less business than in the Spring of 1933. 
The Meeker Co. evidently was no exception, and the loss of 
33 l/3$ in volume of sales was not due to any reasons 
given by them. 

"Another handicap to which consideration should be given is on 
account of our long distance from' material market we are compelled 
to carry heavy inventories that J the eastern manufacturers do not 
have to carry. " 

The necessity for carrying heavy inventories cannot be 
attributed to KRA, nor does it justify a lower wage rate 
to be paid to workers. 

"Relative to a wage differential which we feel we are justly 
entitled to under the circumstances as enumerated, it should 
be borne in mind that the cost of living in Joplin, Missouri 



9811 



-416- 

is much less than the cost of living in the- eastern and 
metropolitan centers. If we were conceded the differential 
which our handicapped position in this afield of -manufacture 
plainly indicated we are entitled to, we : would be in a posi- 
tion to employ more labor than we are able to employ at 
present, as we could again resume lines we have had to dis- 
continue, thus being more of a benefit to our community and 
be on a better basis as a firm. The Meeker Co. has been in 
-business more than 25 years, and has never been located any- 
where except here in Joplin. Our products are sold to de- 
partment stores and other retail outlets throughout the en- 
tire United States." 

The cost of living in Joplin, Mo. is no less than it 
is in Sussex, Hew Jersey, Clinton, Mass. , or Boyertown, 
Pa., or other towns in which handbag factories are lo- 
cated. In the New York area the workers are paid about 
50,3 more on the average than the Meeker Co. pays its 
employees on the average, and unless the Meeker Co. 
seeks to maintain the lowest living standards in Joplin, 
Mo. there is no justification for their claim on the 
basis of lower living costs in Joplin, Mo. 

"Another handicap of some importance is that in selling our 
product in so?ne of the big eastern cities, particularly Hew 
York City, to, make such sales we are compelled to pay the 
transportation charges to the customer to equalize the trans- 
portation cost with th<± of the manufacturer in Hew York close 
to the customer where no transportation charges are involved." 

It is true that they are at a disadvantage when they 
try to sell their product in Hew York City where one 
hundred manufacturers are located-, sufficient to care 
for all the needs of the trade in Hew York. On the 
other hand, a New York manufacturer is at a disadvan- 
tage if he tries to sell his product in Kansas City, 
Missouri in competition with the Meeker Co. Ho re- 
tailer in New York City is willing to buy goods in 
Joplin, Mo. and pay transportaion charges, when he can 
boy goods of equal value and style in his own market,., 
delivered free of charge.' The real purpose of a Hew 
York selling office for a factory far removed from 
Hew York, is for the purpose of selling to out of town 
. stores who visit the Hew York market. 

"Another angle to our situation is that while we are the 
only ha.ndbag manufacturer in our- town, or for that matter, 
in this entire section, - in fact, the largest handbag 
manufacturer west of the Mississippi River - there are in 
our city garment manufacturers, and other manufacturers in 
other towns in our immediate vicinity. Also, there are a 
number of shoe manufacturers not in our city, but in our 



9811 



-4-17- 

vicinity, none of whom pre compelled to gr^y the high minimum rate of pay 
which we have, and all other lines of such manufacturer have a learners 
provision in their Code, whereby they can employ green help for a certain 
length of time at QOjo of the minimum wage until they learn, at least in 
a measure, how to perform the work they are doing in a satisfactory vol- 
ume. Of course, in these other lines where there are a lot of shoe fac- 
tories in the state, a lot of garment manufacturers in the State, they 
had sufficient representation when their codes were formulated to exert 
an influence so as to enable them to get fair consideration . We have 
had no one to cooperate with us in our line of manufacture. Therefore, 
the Code was formulated and out into effect and is being operated today 
solely from the viewpoint of the eastern or Hew York manufacturers and 
no consideration given to our concern. " 

If conceded a differential in wage rate, the Meeker Co. claims they 
would be in a position to employ more labor. The situation would 
apply alike to any manufacturer in the industry wherever located, 
if he were accorded this advantage over all of his competitors in 
the industry. 

"We cannot maintain a representative in Washington to attend all the 
hearings and make effort to get conditions or rulings that we are justly 
entitled to. Therefore, our condition must be relived or else we vrill 
be compelled to pass out of this line of manuf acture , as much as we 
would regret to do so. If we are forced from this field of manufactur- 
ing, it will mean the loss of employment for around 200 people, leaving 
our town without a payroll which is much needed, and many heads of fam- 
ilies without employment and us with a lot of equipment for which we 
will have no use. Our progress in this field will have been made in vain. " 

The Meeker Company's plea that they are alone in this particular 
territory is not due to any unfortunate circumstance. They evi- 
dently intended it to be an advantage, otherwise they would not have 
made it their choice. After 25 years, they have just come to the 
realization that they are isola.ted. The manufacture of handbags is 
not a matter of geographical location. It is mostly the efficiency 
of operation in a plant, no matter where located. We find the most 
efficient plants, those doing the largest volume of business, lo- 
cated in cities in Pennsylvania and Connecticut. These plants are 
operating efficiently; their management is alive end wide awake, 
employing and creating new systems and machinery to produce their 
product at the lowest costs, while paying Code wages and more. 

"In general, the Code we are operating under now, that is functioning 
against the interest of our business, is forcing us out of lines of manu- 
facturing, anu if continued, will in all probability force us entirely 
out of the handbag business, and to which we are compelled to pay Code 
fees that last year amounted to more than $1,000.00 a year during \7hich, 
on account of the restriction under which we are compelled to operate, 
the heavy taxes of one kind or another that we have to pay, caused us to 
do a year's business not at a profit, but at a heavy net loss for the 
year's operations, a loss we cannot continue to bear." 



9811 



-418- 

As far as we know, NRA has not put a single handbag manufacturer 

out of "business, hut if exceptions to the wage rates are granted 

to one or a few in the industry, it is likely to put a great many 

out of "business. 

The Code fees paid "by the Meeker Co. during the past year were on the 
same "basis paid "by everjr other member of the industry. Besides, 25$ of 
the amount that was paid by each member was refunded. 

STATISTICS 
The chart shows the number of workers employed by the Meeker Co. for 
each month reported from the effective date of the issuance of labels, 
July 2, 1934. The peak month was 226 workers, the low, 112 in the month 
of July, which normally is the slowest production month of the year. 

In the peak month, 148 out of a total of 213 workers employed received 
the minimum wage of 35^- an hour, and only one worker received over $35. 
a week. In the dullest month, July, 81 workers out of 112 received the 
minimum wage of 35<z!- an hour, and only one worker received over $35. a 
week. 

The Meeker Co. manufacture handbags that retail from $2.95 to $10.00 
each. They have a reputation for making a clean, well made product, 
which can only be produced by experienced workers. 

Their volume of sales on handbags for the year was, $340,493, If, as 
stated by the Meeker Co. this amount is 33 l/3ja less than their normal 
business, their production of handbags would amount to more than 
$500,000 a year in a normal year. In auu.it ion to handbags, they manu- 
facture an extensive line of men's wallets and novelties, which do not 
come under the ladies' handbag code. 

Erom our knowledge of existing conditions in the industry, also from a 
personal investigation of the plant and working conditions made by the 
Code Director of Compliance, Max Berkowitz, and based upon the statistics 
of their business furnished by the Meeker Co., we are convinced they are 
not entitled to an exception to the Code requested by them. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG IUKJSTBY 

A. Llittenthal 



Code Director 



9811 



-419- 

MESKER COMPANY 
JOPLIN, MO. 

PAYROLL STATISTICS 





Number 




of 




Employ- 


mONTH 


ees 


Jul-/, 1934 


112 


August, 1934 


164 


September, 1934 


178 


October, 1934 


226 


November, 1934 


213 


December, 1934 


122 


January, 1935 


138 


February, 1935 


138 


March, 1935 


118 



dumber number Number Number 

Earning Earning Earning Earning 

$14 per $15 to $20 $20 to $35 $35.00 

week per week per week and up _ 



81 

110 

115 

139 

148 

76 

88 

92 

76 



19 
34 
42 
49 
41 
25 
28 
24 
22 



11 
19 
20 
28 
23 
20 
21 
21 
19 



1 
1 
1 
1 
1 
1 
1 
1 
1 



SALES REPORTS 
Larch 26, 1954 to March 25, 1935, Inclusive. 



March 26 through March ol, 1934 $5,100.00 
April ) 

May ) 59 , 44S , 00 
June ) 
July ) 

August, 1934 33,6b2.00 

September, 1934 37,599.00 

October, 1934 53,632.00 

November, 1934 70,327.00 

December, 1934 15,753.00 

January, 1935 6,504.00 

February, 1935 27,435.00 

March 1 through 25, 1935 26,052.00 



$340,493.00 



9811 



-420- 



May 2, 1935 



Mr. C. Meeker 

President, The Meeker Company, Inc. 

Joplin, Missouri 

Dear Mr. Meeker: 

Your letter of April 30 with its enclosures, 
addressed to Mr. Walter Uangum, Deputy Administrator, of 
this Division, lies "been received during his absence. 

A letter addressed to Mr. uangum on the same 
subject has just been received from the Honorable Dewey 
Short, Congressman. 

As Mr. ..langum had the interview with him and 
with Mr. Cleveland A. ITewton to which you have referred, 
we are simply acknowledging receipt of your letter with- 
out attempting an extended reply. 

We expect Mr. Mangum back within a day or two 
and we will refer botu letters to him promptly upon his 
return. We are confident that he will wish to give these 
letters his personal attention and the careful considera- 
tion that the importance of the matter deserves. 

Very truly yours, 



Owen A. Locke 
Assistant Deputy Administrator 
Textile Division 



9811 



-421- 

THE MEEKER COMPANY, INC. 

Fine Leather Goods 

Joplin, iviissouri 



April 30, 1935 



Mr, Walter Mangum, Deputy Administrator 
Textile Division, N t R. A. 
Washington, D» C. 

Dear Mr. Mangum: 

With further reference to yours of April 13th, I am enclosing here- 
with, as you h^ve requested, balance sheet for the years 1933 and 1934. 
These balance sheets are taken out of our public accountant's annual 
report on our business. These accountants are Baird-Kurtz & Dobson, 
Joplin National Bank Building, Joplin, Missouri, We can furnish you 
further information if such is necessary, or you can if you wish 
communicate direct with these accountants. 

I am also enclosing what I think is the information asked for in the 
second paragraph of your letter. You will note we show for -Cebruary 
and March a big shrinkage in the number of people employed and when 
consideration is given to the fact that all employees for the months 
reported, although many of them working only part time as the total 
hours will show and a smaller amount of goods manufactured, you can 
readily see how our business has deteriorated. April would show as 
bad or worse condition than March, 

Mr. Cleveland A. Newton has just written me relative to the interview 
that he, in company with Congressman Dewey Short, had with you recently, 
and has advised that the New York crowd insists we are making money 
hand over fist. These New York fellows know our position, but as I 
previously advised, it is my opinion, based on experience, that they do 
not care abything about our position in this industry. It is my honest 
opinion that they feel that the handbag manufacturing business is an 
eastern business, I might be wrong in some of my conclusions regarding 
these fellows in the east, but I don't think so. 

In a bulletin put out by the Code Authority dated '"arch 21st., they 
list ninety-one cases pending for non-compliance with the Code. I wonder 
if you felloes in Washington know the details of these non-compliance cases. 
Of course, I do not, but it wouldn't surprise me if many of them were 
not in the same class as that of the Virginia Art Studio of Lynchburg, 
Virginia who apparently have never complied with the minimum wage, and this 
concern in Lynchburg is perfectly justified in my opinion in not complying. 
It is reported I think that the Virginia Art Studios are doing a big busi- 
ness. They nay be, but at this time of the year they manufacture a parti- 
cular tyne of bag that forms a big part of their year's business, and if it 
looks like they are doing a big business in recent months it isn't because 
they are taking advantage of the lower wages they are paying, but on ac- 
count of the seasonal bags they are making. 



9811 



-422- 

When the Code went into effect we asked for exceptions to the minimum 
wage, filing our "brief in due form and going "before one of the Darrow 
committee in Kanses City, a Mr, Mann, explaining our position and while 
waiting for a decision we had in effect a minimum of 30^ per hour for 
some of our help. Yet the Code Authority when they got ready to issue 
labels would not ship us la"bels until we had paid back about $800.00 
that they termed back wages to bring the minimum up to $14.00, or 35(? 
per hour. And now I find that the Virginia Art Studios have labels 
in their product, yet have not been compelled by the Code Authority to 
pay the Code minimum, and there may be others among the ninety-one non- 
compliance cases operating as this concern is. 

All of this may not be of interest to you in the situation, yet I think 
it does show that we haven't been treated fair under the Code. I am 
not complaining against the Lynchburg, Virginia concern; their position 
is somewhat similar to ours and they should not be made to come under 
the Code on the same basis as the New York and that particular vicinity, 
where nearly all of the manufacturers are located, with their market for 
raw material and everything that goes into handbags except labor, right 
at their door. 

In considering our case, I wish you would again refer to our brief, 
left with you. These New York fellows claim a great success for the 
Code, yet they have ninety-one cases of non-comoliance out of three hun- 
dred and thirty-seven manufacturers that they claim are in the industry, 
and during the past few weeks they have allowed the eastern manufacturers 
to dump merchandise on the market at orices it could not be produced for 
until the Easter market was virtually demoralized. When I was East re- 
cently the New York papers were full of special sales on fine handbags 
at ridiculously low prices, yet every producer of these bags was under 
the Code, that the New York crowd claims is such a grand success. 

The Code has worked nothing but a hardship on us. As I previously ad- 
vised, in our vicinity there are show manufacturers, shirt manufacturers, 
cigar manufacturers, and others, none of whom have the high minimum wage 
that we have, and all of them have a period in which they can work an 
absolutely green employee for a certain length of time until they get 
familiar with their work at less than the minimum; 80,o of the minimum 
in most cases, I think. One garment manufacturer who employ about one 
hundred people here in our town are able to work their new people whom 
they are trying to teach the business at 50$ of their $12.00 minimum 
for several weeks. Shoe concerns at 80$ of the minimum for six weeks 
and they have a minimum for female labor of 30f£ per hour. Cigar manu- 
facturers here, and thereSare two of them, I understand from very re- 
liable authority, paid little or no attention to the Code minimum. 

So all in all, I know that no consideration has been given to our iso- 
lated position in this industry. 

I am enclosing you a letter that will at least enlighten you as to the 
New York crowd's attitude toward us when the Code was being formed. 
This letter from Mr. Mittenthal I will ask you to return. I don't like 
to go on record as being constantly complaining against these fellows, 



9811 



-423-. 

but I have a "business here to maintain; not a rented loft like most of 
these fellows, but a big investment, as you '.Till note from my balance 
sheets. A building and equipment which we own. On account of this it 
is rather hard to arrive at a decision to pass out of any manufacturing 
line; leaving buildings and equipment idle and throwing peonle out of 
work, many of whom have virtually been raised up in this business, a 
business I have been more than twenty-five years in developing and de- 
voting my energy to. 

Now if I haven't given you details that you want, just call on me; I 
want you to know that I appreciate the courtesies extended me when I was 
in your office recently by yourself, Lir. Smith and Mr. Hill. Any deci- 
sion you arrive at will be satisfactory and if you wish I can come to 
Washington again, although it is a long trip. The same day I called on 
you I called on lir. Howell Cheney, whom I supplied some figures to which 
he may have passed on to you, and with whom I have had considerable cor- 
respondence with in recent months and who seemed to feel' when I talked 
to him in his office that our situation out here really deserves some 
consideration. 

Trusting that I have not bored you or indulged in any unnecessary com- 
ments on the situation, I am 



Yours very truly, 

/S/' C MEEIIER 
President 
THE MEEKER COMPANY, INC. 



P.S. On our balance sheet under assets you will note listed sales- 
men's accounts overdrawn. This reflects the earnest effort we have 
made to keep our business going since the depression set in in advanc- 
ing salesmen money to keep them going, thereby keeping our factory going 
and keeping our people employed; money we have expected to recover from 
the salesmen when our business again got back on a better basis. 



9811 



-424- 



May 4, 1935 



The Honorable Dewey Short 
House Office Building 
Washington, D. C. 

My dear Congressman Short: 

Your letter of April 26 with enclosure, 
addressed to Colonel Walter Mangura, Deputy Adminis- 
trator, was received during his absence this week 
and was acknowledged by telephone to your Secretary. 

Colonel i.iangum, who has been giving this 
matter his personal attention since you and Mr. New- 
ton called upon him the other day, informs me that 
he has already been 'in touch with the Code Authority, 
that the matter is having proper attention and will 
be followed closely in order to insure full considera- 
tion at the earliest possible moment. 

Sincerely, 



Prentiss L. Coonley 
Code Administration Director 



Textile Division 



9811 



-425- 

CONGRESS 0? THE UNITED STATES 
House of Representatives 
Washington, D. C 



April 26, 1935. 



Col. Walter Mangum 

Deputy Administrator, N.R.A. , 

Washington, D. C. 

My dear Colonel Hangum; 

I beg to present a tragic situation and respectfully urge 
your sympathetic consideration. 

About twenty-five years ago, the Meeker Company established 
a ladies' handbag factory in Joplin, Missouri. This industry grew un- 
til it becajae one of the most successful una attractive plants in that 
great agricultural and mining area. 

The Code Authority of the Ladies 1 Handbag Industry seem 
unable to understand the difficulties and handicaps under which this 
Company is compelled to operate, and as a result of the burdens im- 
posed, they have lost money co .tinuously since the Code became effec- 
tive. Unless relief is granted very soon, they will be compelled to 
shut down their plant, and, of course, the employees will lose their 
source of livelihood. 

I am sure it is not your purpose, nor is it the purpose 
of, the National Recovery Act to destroy a useful industrial plant. 
Approximate^ ninety per cent of the ladies' handbags are manufactured 
in New York. The Code Authority is established there, and while its 
members understand their problems, they have had no experience in a 
factory such as the Meeker Company is operating. 

The Ladies' , Handbag Code at the time of the public hearings, 
contained a labor diff erential between factories in large cities and 
those in rural municipalities. When the Lieeker Company received a copy 
of the Code as finally approved, this differential had been eliminated, 
and it is impossible for them to continue operating without an adequate 
labor differential. 

The Meeker Company is 1440 miles away from Hew York and 
hundreds of miles away from another handbag factory. The materials and 
supplies used in handbags outside of leather, are manufactured in the 
vicinity of 1'ew York plants, while this Company is compelled to bear a 
substantial burden for freight and express in shipping these supplies to 
the factory. It is also compelled to lay in supplies of stock which 
calls for capital investments, not required ay the Hew York companies 
because of their proximity to the source. 

The Meeker Company is compelled to send representatives 
at frequent intervals to New York, not only to buy supplies, but to 

9811 



-426- 

study and observe the styles and any developments in order to keep a- 
breast with the industry. This expense is not required "by the Hew York 
factories. 

The handbag industry has a seasonal production. Its prin- 
cipal market is during the Holidays. It necessarily employs aboiit twice 
as much workers during the last hall' of the year as required for the 
first half. The Hew York companies have an abundance of skilled labor. 
The Lieeker Company has no supply upon which to draw, and when the plant 
needs additional labor around the first of July, it is neces r ;ar r to use 
raw and unskilled workers, while the Hew York plants get an abundance 
of skilled labor. 

Under the Code, the Lieeker Company is compelled to pay the 
full minimum wage to these new and untrained workers, a burden which 
the Hew York factories are not required to bear. 

There are a number of shirt, overall, and shoe factories 
in the Joplin territory, and none of then are required to pay mininum 
wages anywhere near as high as the ladies' handbag Code requires. As 
a result of these handicaps, the Lieeker Company nas already been forced 
out of a number of lines of production with a result that its number of 
employees are now greatly reduced from what they were at this time last 
year. 

An investigation of living costs has been made, based 
upon the United States Department of Labor statistics, which shows that 
workers in Joplin, Missouri, can live with the same comforts and neces- 
sities of life at less than sixty-five per cent of the cost required by 
the workers in Hew York. The carfare alone, required of the Hew York 
workers, is enough to justify a substantial differential over the Jop- 
lin workers, who have no such expense. Llany other items could be en- 
umerated. 

The Lieeker Company made an application to the Code Author- 
ity months ago, to be relieved from the handicaps which are destroying 
the industry. It has received no sympathetic cooperation, and I res- 
pectfully call your attention to Sec. 3 of Art. 4 of the Code of ?air 
Competition for the Ladies' Handbag Industry, v.'hich reads as follows: 

"The Administrator may, under exceptional circumstances 
and upon such conditions as he may arescribe, permit a member 
of the Industry to employ learners at rates below the minimum 
wage herein established. " 

Because of the tragic problem with wnich the Lieeker Company 
is confronted, I respectfully urge that you exercise the power invested 
in you under the Code and that you make such modifications and changes 
as will remove the handicaps which the Company is suffering and which will 
save this industry from destruction. 



9811 



-427- 

The Meeker Company has obeyed the Law, It has lived up to 
the provisions of the Code, and the sua total of the results thus far, 
is that it is paying approximately $1000 per year in dues to the N.R.A. , 
while moving nearer and nearer to ruin. 

Sincerely Yours, 



Dewey Short 
Member of Congress 



?. S. I herewith attach some living cost data prepared "by the Statis- 
tical Department of the St. Louis Industrial Club, which will show the 
living cost in New York to be at least one-third higher than in Joplin, 
Missouri. 



9811 



-428- 



COST 0? LI' r Ii\ T G 



The United States Bureau of Labor Statistics for the year 1933 
determined the cost of living for an average family of four persons 
where the head of the family earned from $900 to $2500 per annum, in 
some 92 cities and towns in forty-two states of the Union. In deter- 
mining the cost of living they ascertained the cost of the consumption 
of items of food, clothing, house furniture, house furnishings, rent, 
fuel, light and miscellaneous items including insurance, amusements, 
taxes, liquor, tobacco, books, travel, newspapers, magazines, doctor 
bills, barber, school expense, telephone, street car fare and so forth. 

On the basis of calculation, it was found that the cost of living. 
for the average working man's family of four persons in 'Jew York was 
$1428, per annum; in Chicago, $1277 per ainura; and in St. Lonis, $1219. 

Since we have no official figures on Joplin, ,.issouri, we set forth 
the following table, giving this calculation, based on the s"Lie items 
included in the calculation for the family in ITew York, for varioaus 
cities and towns which conditions are similar to those in Joplin, and 
certainl3 r the cost of living v:ould not be hi ;her in J.oolin than in the 
following cities: (Tne lomlation in Joolxn, Missouri, is approximately 
33,000) 



City 

Hannibal, Mo. 
Belleville, 111. 
Decatur, 111. 
Springfield, 111. 
Danville, 111. 
Jacksonville, 111. 



Fo ml.-ition 


Cost 


of Living 


jo of New York 


22,761 




$900 




63.03$ 


28,425 




894 




6'?. 46,0 


57,512 




8^5 




61.9,1 


71,864 




376 




61.34$ 


36,765 




670 




60.9,0 


17,747 




853 




59.73$ 



9811 



-429- 

CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

347 EIETH AVEFJE 

HW YORK 



lay 13, 1935. 



Mr. 0. W. Pearson 
NRA Headquarters 
45 Broadway 
New York City 

Dear Mr. Pearson: 

We are enclosing a copy of the latest communication received 
by the Administration (from the i.ieeker Company, Joplin, Missouri, a 
copy of which they forwarded to us. 

We are also enclosing a copy ox the accompanying letter writ- 
ten "by Mr. Locke, a copy of the personal letter written by Mr. Mitten- 
thal to his personal friend Mr. C. Meeker on February 28, 1934 before 
our code was approved, and a copy of our reply giving the facts refut- 
ing the statements made by the Meeker Company. 

We trust you will approve of the reasons we have given in 
our reply to the statements made by the Meeker Company. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 



Mitt en thai 

Code Director 



9811 



-430- ■ 

May 21, 1935 

Mr. A. 1/Iittenthal 

Code Director, Code Authority 

Ladies 1 Handbag Industry 

347 Fifth Avenue 

New York, N. Y. 

Dear Mr. Mittenthal: 

Under separate cover we are mailing to you a copy of our let- 
ter of May 20 to Mr. Meeker, president of the Meeker Company of Joplin, 
Missouri. 

This will inform you of our decision regarding this matter 
and will also serve as acknowledgment of your letter of May 16, in which 
you advised us that his petition was disapproved by the Code Authority 
in a vote "by mail. 

We are most appreciative of the large amount of time and care 
you have given to the consideration of this case. 

Very truly yours, 

Owen A. Locke 
Assistant Deput;^ Administrator 
Textile Division 

CC: Mr. 0. W. Pearson, Administration Member 



CODE AUTHORITY 

LADIES' HANDBAG- INDUSTRY 

347 FIFTH AVENUE 

NEW YORK May 16, 1935 

Mr. Owen A. Locke 
Assistant Deputy Administrator 
Commerce Building 
Washington, D. C. 

Dear Mr. Locke: 

The Code Authority, by mail vote, has denied the petition of 
the Meeker Company, Joplin, Missouri, for permission to engage learners 
at less than the minimum Code wages. The request was denied for the 
reasons given in our answers to the Meeker Company's petitions. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 

/S/ A. Mittenthal 



A. Mittenthal 

Code Director 
9811 



-431- 



May 15, 1935 



Mr. A. Mittenthal 

Code Director 

Code Authority Ladies 1 Handbag Industry 

347 Fifth Avenue 

New York, New "fork 



He: The Meeker Company, 
Joplin, Mis? car i 



Lear Mr. i.iittenthal: 



We have ycur letter of May 13 on the above subject and we 
axe most appreciative of the trouble you have taken to answer the 
various points raised by Mr. Meeker. We are particularly glad to 
have the comparison of wages paid by the factories in New York City 
and those paid "oy the Meeker Company. 

We would like to give this information and the other latest 
information that you have given us, as well as your previous letters, 
thorough study and consideration. We have asked Mr. Meeker for cer- 
tain additional information and will try to reach a decision as soon 
as possible after \ie have received his reply. 

Very truly yours, 



Owen A. Locke 
Assistant Deputy Administrator 
Textile Division 



9811 



-432- 

CODE AUTHORITY 
LADIES HANDBAG- INDUSTRY 
347 Pifth Ave. 
HEW YORK 



Llay 13, 1935 



Mr. Owen A. Locke 

Assistant Deputy Administrator 

Commerce Bldg. 

Washington, D. C. 

Dear Mr. Locke; 

We are in receipt of your letter of May 7 regarding the case of 
the Meeker Company, Joplin, Missouri. We note the additional 
reasons they give to entitle them to an exemption from the wage 
rates of the Ladies' Handbag Code. We shall try to answer their 
arguments and give additional facts in support of our answer to 
the arguments given in their previous letter 

"With further reference to yours of April 13, I am enclosing herewith, 
as you have requested, balance sheet for the years 1933 and 1934. These 
balance sheets are taken out of our public accountant's annual report on 
our business. These accountants are Baird-Kurtz & Lobson, Joplin Nation- 
al Bank Building, Joplin, Missouri. We can furnish you further informa- 
tion if such is necessary, or you can if you wish co.omunicate direct 
with these accountants." 

We accept as correct the statistics furnished by the United States 
Bureau of Labor as to tne relative cost of living between Joplin, 
Missouri and New York City as being 63.03$ the same as it is in 
Hannibal, Missouri, a city mentioned specifically in this report. 

We have prepared a chart which will show the wages paid per hour 
in handbag factories located in Hew York City. In order not to 
disclose the names of the factories, we have nunbered them from 1 
to 5. We have also prepared a similar chart showing the wages paid 
to workers per hour in the factory of the Meeker Company. These 
figures are taken from the payroll records submitted by the res- 
pective manufacturers and examined as to their accuracy by our in- 
vestigators. In preparing these figures, we have taken the same 
month of the year for all factories, November 1934. The New York 
factories, from whose payrolls these figures were taken, manufac- 
ture handbags comparable in style, quality and price with those 
manufactured by the Meeker Company. 

It is interesting to note that while the cost of living in Joplin, 
Missouri is 63. 03$ of what it is in New York, the wages paid by 
the Meeker Company are about 50$ of the wages paid to the workers 
in New York. It is evident tnat the Meeker Company has already 
anticipated the difference in living costs between Joplin, Missouri 
and New York City. 



9811 



-433- 

The union scale of minimum wages. for first class cutters, Operators, 
pocket oook-makers, framers, end oarers, which comprise the five ma- 
jor classifications of operations on handbags, is $37.54 for 3?2 
hours of work per- week, or at tiie rate of $1.00 per hour in i\ew 
York. There are many workers who receive considerably more "because 
of their skill or length of service. 

The rate for second class workers is $33.60 for 3?-/ hours of work 
per week, or about 900 per hour. The Union's scale of minimum wages 
for helpers "is "$23.48 for 37 : j hours of work per week or about 65^ 
per hour. We understand that a great deal of the work in the fac- 
tory of the Meeker Company is performed on a_ piece work basis, and 
that the piece work rate is based on the minimum wage of 35^ per 
hour. This fact is borne out by the payroll record of the Meeker 
Company, which shows that 148 out of 213 workers earned the mini- 
mum code wage of 35^ an hour. The piece work rate under Union agree- 
ment in New York factories is $1.11 an hour. 

The balance sheet of the Meeker Company does not give all the infor- 
mation necessary for an analysis of the operations of their business. 
We cannot determine the items included in labor costs direct and in- 
direct, neither do we have a separation of the various branches of 
their business, parts of; which are included under ' another code. 
Without their operating figures, we cannot express an opinion as to 
the reason for their having incurred a loss in their business for 
the year 1934. The loss may have resulted from the operations of 
some other branch of their' business. We might say, however, in gen- 
eral, that losses throughout the handbag industry were not unusual 
for the year 1934. 

"I am also enclosing what I think is the information asked for in the 
second paragraph of your letter. You will note we show for February and 
March a big shrinkage in the number of people employed and when consider- 
ation is given to the fact that all employees for the months reported, 
although many of them working only part time as the total hours will show 
and a- smaller amount of goods manufactured, you can readily see how our 
business has deteriorated. April would show as bad or worse conditions 
than March. " 

The chart submitted by the Meeker Company shows that for the first 
three months of operation in 1935 when the code was effective, 
against the first three months of 1934 previous to the code, there 
was a decline of 36J>fo in the number of hours worked and only a de- 
cline of 24^$ in the -value of the product produced, which is proof 
that they operated more efficiently in 1935, and even though they had 
to pay the increase in the minimum wages, they produced a greater 
volume of sdes from the hours worked. 

It is true that the dollar volume of. sales during the month of March, 
1935 shows a decided decrease, but the entire industry had a very 
poor spring season in 1935 and, as a, consequence, losses averaged 
from 33-1/3$ to 50$ in sales volume were quite general. The Meeker 
Company show a loss in sales volume for the first three months of 
1935 of 24.3$. 

9811 



-434- 

"lvlr. Cleveland A. Newton has just written me relative to the interview 
that he, in company with Congressman Dewey Short, had with you recently, 
and has advised that the How York crowd insists we are making money hand 
over fist. These New York fellows know our position, "but as I previous- 
ly advised, it is' my opinion, based on experience, that they do not care 
anything about our oosition in this industry. It is my honest opinion 
that they feel that the handbag manufacturing business is- an eastern 
business. I might be wrong in some of my conclusions regarding these 
fellows in the east, but I don't think so." 

This is only an unsupported expression of opinion. 

"In a bulletin put out by the Code Authority dated i.iarch 21, they list 
91 cases pending for non-compliance with the Code. I wonder if you fel- 
lows in Washington know the details of these non-compliance cases. Of 
course, I do not, but it wouldn't surprise me if many of them were not 
in the same class as that of the Virginia, Art Studio of Lynchburg, Vir- 
ginia, who apparently have never complied with the minimum wage, and 
this concern in Lynchburg is perfectly justified in my opinion is not 
complying. It is reported I think that the Virginia Art Studios are 
doing a big business. They may be, but at this time of the year they 
manufacture a particular type of bag that forms a big part of their 
year's business, and if it looks like they are doing a big business in 
recent months it isn't because they are talcing advantage of the lower 
wages they are paying, but ®n account of the seasonal bags they are mak- 
ing. » 

The 91 cases of non-compliance pending cover all kinds of cases of 
non-compliance under the code. Surely, the Lieeker Company does not 
intend to justify their right to an exemption to the code for the 
reason that others have not complied 'with code provisions. The 
facts in the case of the Virginia Art Goods Studios are well known 
to the Administration. No exemption has ever been granted to the 
Virginia Art Goods Studios by the Code Authority of the Ladies* 
Handbag Industry. 

"When the Code went into effect we asked for exceptions to the minimum 
wage, filing our brief in due form and going before one of the Darrow 
Committee in Kansas City, a Mr. Mann, explaining our position and while 
waiting for a decision we had in effect a minimum of 30<? per hour for 
for some of our help. Yet the Code Authority, when they got ready to 
issue labels, would not ship us labels until we had paid back about 
$800. that they termed back wages to bring the minimum up to $14.00, or 
35f£ an hour. And now I find that the Virginia Art Studios have labels 
on their product, yet have not been compelled by the Code Authority to 
pay the Code minimum, and there may be others among the 91 non-compli- 
ance cases operating as this concern is. 

"All of this may not be of interest to you in the situation, yet I think 
it does show that we haven't been treated fair under the Code. I am 
not complaining against the Lynchburg, Virginia concern; their position 
is somewhat similar to ours, and they should not be made to come under 
the Code on the same basis as the New York and that particular vicinity, 
where nearly all of the manufacturers are located, with their market for 
raw material and everything that goes into handbags except labor, right 
at their door. " 

9811 



-435- 



The report by the Barrow Board, we believe, was made up of just 
such hearings referred by the i/ieeker Company, and is probably 
the reason why the report of the Darrow Board did not meet the 
approval of the Administration. 

The reason for tne payment of restitution of ,£800. by the 
Meeker Company was because they violated the labor provisions 
by paying less than the minimum code wages. This restitution 
was paid to every worker entitled to receive it. 

■ n •» r i * .i 

"In considering our case, I wish you would again refer to our brief 
left with you. These New York felloes clai/a .?. great success for the 
Code yet they have 91 cases of non-compliance out of 337 ma,nuf acturers 
that they claim are in the industry, and during the past few weeks they 
have allowed the eastern manufacturers to dump merchandise on the mar- 
ket at prices it could not be produced for until the Easter market was 
virtually demoralized. Uhen I was East recently the Hew York papers 
were full of special sales on fine nandbags at ridiculously low prices, 
yet every producer of tnese bags was under the Code, that the Hew York 
crowd claims is such a grand success." 

The Administration do&s not allow us to.". fix prices. i.;We- camipt 
[control the wholesale prices, and certainly not the retail-prices 
'..-at which bags may be sold. , 

"The Code has .worked nothing but a hardship on us. As I previously 
advised, .in oar vicinity, there are shoe manufacturers, shirt manufac- 
turers, cigar manufacturers and others, none of whom have the high mini- 
mum wage that we have, and all of them have a period in which they can 
work absolutely green employees for a certain length of time until they 
get familiar with their work at less than the minimum; 80, o of the mini- 
mum in most cases, I think. One garment manufacturer who employs about 
one hundred people here in our town are able to work tneir new people 
whom they are trying to teach the business at 50 o of their £12.00 mini- 
mum for several weeks. Shoe concerns at 80 ;l3 of the minimum for six weeks 
and they have a minimum for female laJbor of 30,;* per hour. Cigar manufac- 
turers here, and there are two of them, I understand from very reliable 

authority, paid little or no attention to the Code minimum, 

a * 

"So all in all I know that no consideration has been given to our iso- 
lated position in this industry. " 

TJe believe this is a criticism of the NBA and not the Code Au- 
thority of the Ladies 1 Handbag 'industry. We do know that shoe 
manufacturers are an excellent source from which experienced 
workers may be procured to do work on handbags. Shoe cutters, 
stitchers and parers are generally considered more skillful 
than workers performing the same operations in a handbag fac- 
tory, and these comprise three of the major operations in the 
making of a handbag f vie are informed there are some shoe fac- 



9811 



-436- 

tories in Joplin, Missouri and in Carthage, Missouri, which 
is only a short distance from Joplin, they should furnish an 
additional labor market for the Meeker Company from which to 
procure experienced workers. - ' "■ ■ 

"I am enclosing you a letter that will at least enlighten you as to 
the New York crowd's attitude toward us when the Cod© was being formed. 
This letter from Mr. Mittenthal I will ask yw to return. I don't like 
to go on record as being constantly complaining against these fellows, 
"but I have a husine-ss here to maintain; not a rented loft like most of 
these fellows, hut a big investment, as you will note from my balance 
sheets. A building and equipment which we own. On account, of this it 
is rather hard to arrive at a decision to pass out of any manufacturing 
line; leaving buildings and equipment idle and throwing people out of 
work, many of whom have virtually been raised up in this business, a 
business I have been more than twenty-five ye^rs in developing and de- 
voting my energy to. " 

The letter written ay Mr. Mittenthal, a copy of ,: :hich was sent 
to the Administration, was a personal letter written to a per- 
sonal friend, Mr. C. Meeker, while Mr. Mittenthal was a member 
of the handbag industry acting as Chairman of the Board of Gov- 
ernors of the Associated Handoag Industries of America, Inc., 
and while he was Chairman of the Code Committee appointed by 
the Associated Handbag Industries of America, Inc. to draft a 
code for the industry. Tne Ladies' Handbag Code was not approved 
until March 14, 1934 and became effective March 26, 1934, so 
that Mr. Mittenthal' s letter -was not written to the Meeker Com- 
pany in an official capacity as Code Director. The opinion ex- 
pressed by Mr. Mittenthal was a personal one, which he held as 
an individual manufacturer at a time when it seemed impossible 
to obtain a code satisfactory to all members of, the industry. 
The dispute involved was whether classification and wage scales 
above the minimum should be included in the code. The New York 
manufacturers who were in contractual relations with the Union 
insisted that they should be included, while manufacturers with 
factories outside of New York City insisted that they should not 
be included, "hen the final code was approved, no classifica- 
tion i.,nd no wage scales above the minimum were included. Pro- 
visions were made in Sections 2 and 6 of Article IV, but they 
were stayed by an Administrative Order approving the Code, and 
still remain stayed. 

We are at a loss to understand why the Meeker Company should 
use a personal letter sent to Mr. C. Meeker to support their 
claim for an exemption to the code 14 months later. 

"On our balance sheet under assets you will note listed salesmen's ac- 
counts overdrawn. This reflects the earnest effort we have made to 
keep our business going since the depression set in, in advancing sales- 
men money to keep them going, thereby keeping our factory going and keep- 
ing our people employed; money we have expected to recover from the 
salesmen when our business again got back on better basis." 

9811 



■437- 



The item "sE.ler.men 1 s accounts" referred to in their balance 
sheet could be shown on almost every trial balance sheet in 
the industry. Only we find other manufacturers properly 
charge such items to profit and loss at the end of the year. 
The Lieeker Company continue to carry it as an asset from 
year to year. It is our experience that this item is sel- 
dom ever realised. Under present conditions with twice as 
many factories striving for one-half of the normal volume of 
business, it is the rule rs.ther than the exception to find 
that four but of five traveling salesmen selling handbags do 
not earn their advanced drawing accounts. We fail to see 
where this situat ion can be attributed to any fault of the 
3TAA, the Code Authority, or the other members of industry. 

We trust this will answer fully the claims of the Meeker 
Company in support of their request for an exemption. 

Very truly yours, 



CODE AUTHORITY 
LADIES' HA1Q3AG IIDDUSTHY 



A. ivlittunthal 



A. Mittenthal 

Code Director 



M:AS 



> 



9811 



-438- 



COMPARISON OF WAGES PAID BETWEEN FACTORIES LOCATED 

IS FEU YORK CITY, AND MEEKER COMPANY OF JOPLIN, MISSOURI, 

FOR THE MOUTH OF NOVEMBER 1934 











AVERAGE 












NO. OF 


EARNED PER 


■ 






PAYROLL 


NO. OF 


HOURS 


WORKER 3ASSD 


AVERAGE RATE 




FIRM 


DURING 


EMPLOYEES 


WORKED 


ON 40-HOUR 


PER HOUR 




NO. 


MONTH 


FOR "7EEK 


FOR WEEK 


WEEK 


PER WORKER 
94|^ 




1. 


1 


54 


2,005 


$35.50 






2 


55 


2,035 


37.70 






3 


52 


1,968 


37.50 


93J0 






4 


51 


1,945 


37.50 


93fj# 






5 


53 


2,047 


35.20 


88^ 




2. 


1 


63 


2,512 


28.30 


72rf 
71p 






2 


63 


2,697 


28.60 






3 


63 


2,503 


29.00 


72§<* 






4 


64 


2,516 


29.25 


73-1/8^ 






5 


64 


2,528 


29.00 


72ij 




3. 


1 


29 


1,087 


30.50 


7&Q 






2 


28 


1,080 


31.20 


78rf 
78 W 






3 


30 


1,139 


31.40 






4 


28 


1,111 


31.30 


78j^ 






5 


27 


1,070 


31.70 


™t4 




4. 


1 


66 


2,362 


31.20 


78^ 






2 


65 


2,411 


32.30 


80-g^ 






3 


68 


2,597 


31.30 


78# 






4 


67 


2,438 


32.60 . 


81-5^ 






5 


59 


1,836 


35.10 


87fr 




5. 


1 


50 


2,421 


37.90 


94^ 






2 


50 


1,886 


37.90 


94f^ 






3 


51 


2, 358 


37.80 


94,^ 






4 


50 


1,964 


39.80 


99 V 










MEEKER 


COMPANY 








1 


209 


7,868 


16.50 


41& 






2 


208 


7,494 


16.10 


40^» 






3 


188 


6,927 


16.30 


40f^ 






4 


152 


5,246 


16.70 


4lf<* 




*P1 ec.se note that 


there were 


five payroll weeks e:ccept 


No. 5 and 




Me eke 


r Co. which 


only had four because different factories -cay 




their 


employees on different 


days of 


the week. 







;811 



•439- 



SCHEDULE 2 

SCHEDULE OE PERCENTAGES OE HOURS AND VALUES OE PRODUCTION EOR 
FIRST QUARTER OE 1935 A3 COMPARED WITH THE EIRST QUARTER OE 1374 

i.IESKSR COLPANY 

1535 



JANUARY 

FEBRUARY 

liARCH 



HOURS TORZED 



Increase 24g- /0 



Decrease 43§ i o 



Decrease 54^,0 



VALUE OF PRODUCTION 



Increase 


57$ 


Decrease 


132/0 


Decrease 


57f /0 



EOR QUARTER OE THE YEAR 
(JANUARY, FEBRUARY & MARCH) 



DE&tEASE 36f$ in hours worked 



l 1 



DECREASE 244 ; i in value 

production. 



9811 



-440- 



|X:iB IT X 

Code Authority Complifince Director 1 s 
Hepo r t on Hr.v e rh i 1 1 , Ma s s . 



9311 



-441- 



EXTIIBIT X 



CODE AUTEOPJTY 
LADIES' iiAUDBAG INDUSTRY 
'303 PIFTi: AVENUE 

' kev; YORK 



April 16th, 1934. 



Mr. 0. v7. Pearson 

N. E. A. 

45 Bbardway 

Kew York, Uew York 

Dep.r Mr. Pearson :- 



I am enclosing herewith cow of the 1p + + ^ *• 
Massachusetts, rel-tin- to L. tter frora Haverhill , 

report. . . * eit ' tint> to home w ^k; also Mr. Berkowitz' s 

You will see from these th-t uv t , 

close invention of fl e'tue/ST- , '" T" * 

the neeeseer, steps tc r^^U^ll^ ""* **" 

Yours very truly, 



(Signed) A^jjjt ten thai 
Code Director 
Ladies' Handbag Industry 



A. Hi t ten thai /TD 



9811 



-442- 

cgde .authority 
ladies' ".-akdbag industry 
503 fift:-: avenue 

HE'./ YORK 



Code Authority April 16th, 1934. 

Gen tl eraen : - 

I hr.ve rar.de an investigation with reference to the manufacturing of 
woven leather handbags in the Haverhill, Mass. district. 

This Industry consists of 12 manufacturers who employ r.bout 2,000 
people. 90,' of this work is done in the homes of women and children. 
I0,o is done in the factories. The work done in the factories con- 
sists of the cutting and only male labor is used in this operation. 
The first manufacturer started in about 4 years ago. The remainder 
are all new firms and they are all located in the cities of Haverhill , 
Ipswich, Lynn and ff. Lynn. Their product is sold to jobbers and in 
a few instances, these jobbers control a large percentage of their 
output. These jobbers are continually trying to break down the price 
of the bag so that the labor costs do not net the workers a living 
wage . 

I have investigated a number of factories and checked up their pry- 
rolls. The workers in the factories receive the minimum wage.- The 
home workers work on a piece work basis; the pay is very low and it 
is impossible to determine the number of hours they work. This work 
is done by all the members of the family. 

I interviewed Mr. George II. Croston, Secretary of IT. R. A. Compliance 
Board, Haverhill, Mass. , and had r> conference with him with reference 
to this matter. He told me it was imp ssible for him to cope with 
the situation. The local authorities are helpless on account of 
pressure brought by the different churches and charitable institutions, 
claiming that it would help a great deal toward welfare work. 

I had a conference with Mr. George Picard, Supervisor of Attendance 
at 'Thittier School, Haverhill, Mass. I questi:ned him with reference 
to the attendance of these children in schools; how they grow up with 
other American children and the children from different parts of the 
city. He told me that the children are rather bright and well 
nourished. However, he is in favor of abolishing this work at home. 
Mis opinion is that it has created a condition beyond the control of 
the local authorities. 

I also interviewed Mr. Edward J. Me eh an, of the Labor Dept. of 520 Bay 
State Building, Lawrence, Mass. he is entirely hel pie ss in enforcing 
any regulations with reference to homework. The State of Massachu- 
setts does not permit any inspector to go in anyone's home without a 
warrant, he can only regulate labor laws as far as factories are con- 
cerned. 

9811 



-44-3- 

In view of the conditions, I interviewed. Liiss Connolly of the Greek 
St. James Catholic School, where the majority of these children 
attend. Slie has assured me that the children are well nourished 
and taken care of and not over-worked. Of coarse this church is 
supported mostly by the workers in the vicinity who work on these 
hags, and therefore her opinion was biased. She agreed if anything 
could be done to have these bags made in the factories, conditions 
would be more satisfactory. I visited 21 homes where these bags are 
made. SFone of them have less than three children and the majority 
between eight and nine, host of the children do this work after 
school hours. Some of the hemes are in a very pitiful condition, 
and this money earned by the children is used not so much for the 
support, but more for little luxuries for the older children of the 
family. The -majority of tiese people are of the °-reek orthodox faith, 
and their morals are very high in view of the fact that the parents 
supervise their children very carefully. They are married between the 
ages of sixteen and eighteen years. The entire colony is a replica 
of a small community from Greece into the United States. 

After interviewing each and every owner of these factories, I called 
a meeting which was held at the St. Nicholas hotel. An Association 
was formed under the name of Haverhill Bag 1,'anufacturers. They agreed 
to immediately systematize their business and have the same women do 
the work "in the factories. 

I have formulated, plans whereby they could increase their production 
and not deprive anyone of a livelihood; in fact increase a great deal 
of the earnings of the people without additional burdens to themselves. 
They have agreed to cooperate to the full extent with the Code Auth- 
ority, and promised to live up to the letter of the law. 

It is my opinion that some good constructive work has been accomplished 
and that homework will be entirely eliminated by these manufacturers. 
I expect to make another Visit to see if the changes that were promised 
had been put into effect. 



(Signed) Max Berkowitz 
Code Director 
TD 



9811 



-444- 



Harch 4th, 1935. 
Haverhill, Mass. 



To the IT. R. A. Labor Dept. 
Dear Sir:- , ■ 

I do cot, .'•-■j*' how to start this letter but first of all I'm e. sweat- 
snop worker "but none as tragic as this. So please listen and help the 
children of Haverhill. For you are the only ones that can do it. I 
say this is a tragic letter. Yes tragic. I do not know what your 
idea of tragic is "but I do think that the most tragic thing to do is 
for fathers to go out and enjoy themselves, not work mind you, while 
their children work and sweat till after midnight. That 1 s what the 
fathers of Haverhill do, especially the test of fathers. They force 
their little cliildren from the age of 9 to 12 to work from 6 o'clock 
in the morning till after midnight. And on what. These handweaved 
bags, that is the specialty of Haverhill. They are weaved all the way 
through. They make not in the shops in Haverhill, "but instead in the 
houses. All the children work nights trying to make those bags till 
1 or 2 after midnight. Then tie next day they do to school all in, 
unable to do their lessons. The teachers complain all the time. 
Lately we got word that the N.H.A. will net allow them to be made in 
the houses but in the shops end the poor kids were overwhelmed with 
joy. But the fathers were all angry. And the children are afraid to 
say an thing. And now they don't know what to do. They made their 
children work while they the fathers went to the coffee houses and 
beer joints and enjoyed themselves, on their children's sweat money. 
While their wives and children slaved themselves. ITJhen they should 
get sleep instead. That's why there is so many sicknesses in Haverhill, 
the germs from that leather brought sickness in all the homes. Do 
you think that's right? Yfciild you. let a thing like that continue? 
You that have the power. Well to continue, the fathers kind of liked 
loafing like that. But now there all flaring up because those hand 
bags cannot be made in the houses. They got lazy. They are afraid 
to go back to work. You mast stop those bags from being made into the 
houses completely. Give the kids a break. Because I didn't get mine. 
I did them ever since I v/as 14 and I'm now 18 years old. And I'm a 
girl and I'm sick and tired of watching little kids losing fun. Make 
the fathers go to work, that's their duty, not their little kids. 
The manufacturers of Phoinix Hovel ty Co., United Bag Co. and Essex 
are using all their power to have made in the homes because they are 
in the money and are afraid to lose a chance like that if we got paid 
properly I wouldn't mind, but to do a whole bag through we get 8h<* 
and it takes almost 2 hrs. for it. So stop them please. Don't give 
them a chance to pull it through. Give the kids a break, if you" 
want them to grow and be real Anerican citizens and not turn their 
faces against America. Like they almost made me. So please use all 
your force to stop hand bags from being made in the houses but instead 
in the shops where they belong. 

Very truly yours, 
A. Sweatworker 

9811 



-445- 

P. S. Nobody picked up co.urage.Jj.0 do tliis they're -.11 afraid of 

their f ".timers and husbands. I had tc do this and write to you. I 

don't dare sign my name or adclesss "because if they find out they 

will certainly kill me. But it's true every word of it. Enclosed 

you will find some pieces to prove it. And here are some addresses 

where they make the kids work till midnight. If you don't believe 

it send secret agents and find out for yourselves. And when you do, 

I know you will stcra it. 

- t * 

* * * * *> * * » 

Primrose St. - #132 - #190 - $L(5§ - $164 - #13 - #14 - #165 

Harrison St. - #165 - #155 - #163 - Also Lewis St. & Maple St. - al- 
most half of Haverhill. i ... 

Maybe they are mixed up a bit but on Harrison St. almost all the 
h uses. Please do something. Let them be done in the shops. 






• A ft * * * p 



9811 



-446- 



:lf:rb 



MIDWEST 

XTD BAG & Si .ALL LSAT 33 '.TARES 
ASSOCIATION 



October 23, 1934. 



Mr. Per r sen 

Code Authority 

Ladies ilan&bag Industry 

347 Fifth Avenue 

Few York, N, Y. 

Dear Mr. Per-rson: 

Attached you will find p. copy of a telegram sent 
to the Code Authority, New Yorh City, with refer- 
ence to a meeting held in Chicago in honor or 
Mr. Berkowit.z. 



Yours very truly, 



U ID. TEST "AKDBAG AND SMALL 
LEAT'ZES WARES ASS'N. 



By H.L.FOHST 



,L. Forst, Sec'y. 



9811 



-,47- 



WESTERN UNION 



October 23, 1934. 



CODE AUTHORITY 
LADIES HANDBAG INDUSTRY 
347 FIFTH AVENUE 
NEW YORK, N. Y. 



AT A METING OF THE MIDWEST HANDBAG MANUFACTURERS HELD 
AT THE BISMARCK HOTEL MONDAY EVENING OCTOBER TWENTY SECOND 
IN HONOR OF MR. M. BERKOWITZ CODE DIRECTOR TEE FOLLOWING 
RESOLUTION WAS ADOPTED — A VOTE OF THANKS BE GIVEN THE 
ENTIRE CODE AUTHORITY ESPECIALLY MR. BERKOWITZ FOR THEIR 
INTELLIGENT AND EXPERT INTERPRETATION OF THE PURPOSE OF 
THE N. R. A. ALSO A VOTE OF THANKS BE GIVEN MR. LI. H. 
BLUMENFELD MIDWEST REPRESENTATIVE OF THE CODE AUTHORITY 
FOR HIS IMPARTIAL ASSISTANCE TO THE MIDWEST MANUFACTURERS 
IN EXPLAINING THE CODE FUNCTIONS. 



MIDWEST HANDBAG & SMALL LEATHER WARES ASS'N. 
M. L. FORST, Secretary 



Charge to: 

Mid-rest Handbag & Small Lea. Wares Ass'n. 



9811 



-448- 



EXHIBIT Y 



Report of A. A. Fisher on the Budget 



9811 



-449- 

EXHI3IT Y 



June 20, 1935 



MEM03AMDuM 



To: Colonel Walter i.iangum 

Deputy Admin i s t rat or, ft a 

Prom: A. A. Pi slier ' ' , 

Assistant Deputy - Staff Representative of 
Textile Division Administrator in Liaison 
with Label Code Authorities 

Subject: Ladies' Handbag Code Authority 

To supplement the. Case History of the above Code 
Authority, the following data pertinent to Paragraph C of the 
Outline of Case Histories, has been obtained from Docketed Budgets 
in the files of the Code Be cord Section of the ■ II. P.. A., audits in 
the files of the Code Authorities Accounts Section, supplemented 
by sn inspection of records kept by the Code Authority at its 
office located at 347 Fifth Avenue, Hew York, Hew York. 

Budgets and Bases of Assessment 

The Code for the Ladies' I-Iondbag Industry was approved 
March 14, 1234, effective March 26, 1934. 

The original Budget was submitted for the period 
Liarch 25, 1934 to Larch 25, 1935 in the aggregate amount of 
$140,180.00 estimated expenditures, with the total gross income 
estimated at $149,993.00. This Budget was approved by Administra- 
tive Order 332-8, May 28, 1934, with the following basis of con- 
tribution authorized by Article VI, Section 7 (f) of the Code; 
l/3 of l)o of the dollar sales volume. Objections having been 
filed with the Administration "Trior to the effective date of said 
Oraer, a stay of Order 332»8 was- aiMrave&,bi/' Adi.iinistrr.tive Order 
332-11, under date of June "''9, 1934." 

A revised Budget for the period March 26, 1934 to 
March 26, 1935 was submitted June 28, 1934 estimating aggregate 
expenditures, for the period, of $133,540.00. Said revised Budget 
in the amount of $133,540.00 vras approved July 16, 1934 with the 
previously approved basis of contribution affirmed (to wit, l/3 
of ljo of the total net dollar volume of sales). 

March 13, 1935 a, new Budget was submitted for the period 
from March 26, 1935 to March 25, 1936, estimating aggregate expen- 
ditures of $110,641.00, broken down into two periods; from 
March 26, 1935 to June 15, 1955 estimated expenditures of 
$31,540.00; from June 17, 1935 to March 25, 1936, estimated expen- 
tures of ^70,101.00. In addition to reflecting a reduction of 



3811 



-450- 



$23,000.00 in estimated expenditures the nerrly subr.ij.tted Budget 
provided for a reduction in the bases of assessment to 1/4 of ifo 
of sales of manufacturers and manufacturing jobbers. Based upon 
an estimated Industry volume of 545,000,000.00, the assessment 
was estimated to provide a total income for the year of $112,500.00. 
The method of collecting assessments to be as follows: sale of 
labels to manufacturers and manufacturing jobbers at the rate of 
J2.50 per thousand labels, the total amount of label sales to be 
credited, as an advance against the assessments. 

Administrative Order 332-25, dated Lay 24, 1935, approved 
the submitted Budget to the extent of $31,540.00 for the period 
fro:: I arch 26, 1935 to June 16, 1935, and subject to an extension 
of the Code by operation of the Ian, conditionally approved the 
budgeted expenditures for the period from June 17, 1935 to 
march 25, 1936 in the amount of $79,101.00. 

The basis of contribution approved by Order 332-25 as 
authorized by Article VI, Section 8 (f) of the Code -.as amended 
was 1/4 of l /0 of gross sales of each member of the Industry, payable 
monthly, provided that members of the Industry shall purchase labels 
to be used on articles manufactured and/or sold at the rate of $2.50 
per thousand and charges paid considered as deposits by members of 
the Industry to be credited at the end of each month, during the 
budgetary meriod. Calculating on the approved basis of contribution, 
(to rrit, 1/4 of Vfo of gross sales) Order 332-25 also provided that 
the $5,000.00 included in the budget for trade development and re- 
search, or any portion thereof, shall not be expended unless such ex- 
penditures shall first be authorized by the National Industrial Recov- 
ery Board. 

Label Sales and Income 

In submitting the last budget March 13, 1935 the Code 
Authority reported: 

Estimate of Label Sales from Larch 26, 1934 to 

June 18, 1934 (date of first sale) 10,000,000 labels 

Kuiber of Labels actually sold from June 18, 

1934 to January 31, 1935 25,262,200 » 

Estimated February 1st to Larch 25, 1935 . 6,000,000 " 



Total Labels estimated applicable to full 

year ending Larch 25, 1935 41,262,200 labels 



9811 



-451- 

For the new "budgetary year from March 26, 1935 to 
:;arch 25, 1936 the Code Authority estimated a probable sale of 
65,000,000 labels, divided into 45,000,000 labels to be sold to 
the 525 present members of the Ladies' Handbag Industry paying 
assessments, and 20,000,000 to be sold to two new groups, (to wit, 
Imitation Leather & Novelties Industry, and Shopping Bags, Bathing 
Bags, etc., Industry) expected soon to be included under the ad- 
ministration of this Code Authority. 

The Ladies' Handbag Industry members subject to the 
provisions of the Code were stated to be 500 unit establishments 
consisting of 325 manufacturers and manufacturing jobbers and 
175 contractors, the latter not being subject to assessment, with 
total employment of 15,000 workers on an estimated annual payroll 
(for 1934-1935) of $9,000,000.00 

Total Industry sales for 1934-1935 were estimated at 
$35,000,000.00 against which assessments had been collected to 
January 31, 1935 on net sales of $26,093,664. 

The mandatory use of labels became effective July 2, 1934 
at $2.50 per thousand, but the first issuance of labels occurred 
June 13, 1934. Prom that date to May 3, 1935 when the records of 
the Code Authority were inspected the following is a monthly tabu- 
lation of regular labels sold to manufacturers and the aggregate of 
sticker labels sold for merchandise on hand July 2, 1934. 

Unit Sales of Labels 

1934 Regular Labels 1935 Regular "Labe ls 

June (from ISth) 1,220,000 Jan. 3,543,000 

July 2,154,000 Feb. 3,092,000 

August 3,529,000 March 3,754,000 

September 3,487,000 April 4,571,000 

October 4,044,500 Hay (to 3rd) 491,500 

November 4,310,000 Total June 13,1934 to 

May 3, 1935 36,607,000 

Total Sticker Label Sales 825,000 

Grand Total Label Unit Sales 37,432,000 

The actual cost of labels to the Code Authority was: 

Regular Labels first 30,000,000 at 40^ per 1.1 2/10 E.O.ii. 

next 10,000,000 at 27^ " " 2/ 10 E.0.L1. 
Sticker Labels first 500,000 at 19 A " " 

next 200,000 at 19^ » " 

last 200,000 at 25$ " " 



9311 



-452- 

Fnen the Code Authority activities uere suspended 
hay 27, 1035 a report of audit for the first budgetary period 
ended harch 26, 1935 vras in course of preparation "by hones & LYwis, 
Certified Public Accountants of 521 Fifth Avenue, her York. The 
latest interim audit report by these accountants was for the period 
fron harch 26, 1S34 to February 28, 1935 (see files of Code Auth- 
orities Accounts Section) fron "hich the foilovdng is summarized: 

Ladies' Handbag 'Code Authority, harch 26, 1934 to February 28,1935: 

Income : 

Assessments of l/3 of 1$ on hanufacturers' 

Reported Sales of $28,166,893.00 $93,809.66 

Advances against Past Due Assessments 3,636.69 

Advances against February Assessments 7,731.25 

Sales of 235,225 Retail Labels $588.10 

Less cost of Retail Labels sold 46.41 541 . 69 

Total Income $105,799.29 

Expenses: 

Cost of 28,354,700 Labels issued 

to hanufacturers $11,228.56 

Salaries: Administration, Com- 
pliance and General 34,078.27 

Rent & Other Operating Expenses 12,356.20 

Office Equipment & Organization 

Expense 7,911.41 

Total Expenses $ 65,574.44 

Surplus of Income over Expenses $ 40,224.85 



Financial Ope rat ions 

At February 28, 1935 the Code Authority had accumulated 
a surplus of Income over expenditures amounting to $40,224.85 
which rras reflected as follovs: 

Cash Balances $42,690.71 

Due fron Handbag hanufacturers 614.43 
Travelling Fund (Redeposited 

3/4/35) 345.27 

Insurance Premiums Unexpired 220.00 

Inventory of Labels on Hand 244 . 03 

Total Assets $44,114.44 

9811 



-453- 
Less 

Dae to Handbag Manufacturers $1,187. 57 
Accoonts Payable C-. Accraed 

Exp en se s 2,702.02 

Total Liabilities • $3,889.59 



Surplus '2/ 28/35 With Code Authority 

as Trustees $40,224.85 

Except during the early weeks or Code Authority opera- 
tions '-hen a temporary bank loan financed initial committments, 
the sale of labels provided ample funds for required expenditures. 

Although the actual income was from assessments on 
manufacturers aid manufacturing jobbers sales at the rate of l/3 
of lfS for the first budgetary year and l/4 of 1$ from March 25,1935, 
the label r?as a powerful instrument in expediting assessment collec- 
tion. Industry members ordered and paid for three weeks' supply 
of labels which were furnished only when the applicant reported 
actual sales for the preceding month. The assessment thereon was 
charged to the applicant and the remittance accompanying the order 
for labels was credited against the assessment so charged. 

In vie'.- of accumulated' and accumulating surplus, the 
Code Authority on Larch 7, 1935 voted the distribution from the 
surplus of $30,000.00 to members" of the Industry in proportion to 
the amount contributed during the budgetary year ending 
Larch 25, 1935. Following the vote, the surplus of $30,000.00 
was thereupon segregated in a special bank account and distribution 
had been made thereupon to the extent of about $23,000.00 at 
Lay 5, 1935. The undistributed balance of $8,742.79 was being held 
awaiting final submission of sales volume figures from certain mem- 
bers of the Industry. 

The actual cash balances in the Code Authority bank 
accounts at the close of business, Lay 3, 1935, was as follows: 

Sterling national Bank d- Trust Company $9,454.83 

Manufacturers' Trust Company 10,416.24 

" " if (Special Acct) 8,742.79 

This Code Authority had no account for restitution of 
the employees' wages as the -policy adopted was to obtain from the 
respective employers checks to the order of the employees which 
were turned over to and distributed by the Code Authority to the 
employees against a receipt retained in the Code Authority files. 

Daring the period of its operations to Larch 31, 1935 
the Code Authority's Compliance Division made 3,158 investigations. 
Restitution of wages to the amount of $14,811.22 was made to 
1,041 employees of 70 firms found non-complying with Code provi- 
sions. On Larch, 31, 1935, 85 cases were pending involving about 
$16,000.00. 

9811 



-454- 

General 

General conplian.ee uith Code provisions uas obtained in 
a very satisfactory' degree through the personality and highly 
constructive activities of the tuo Code Directors in charge res- 
pective!;'' of the Adninistration and Conpliance Divisions. The 
Coripliance Director made frequent personal surveys of Industry 
establishments and obtained hearty cooperation throughout the In- 
dustry. 

monthly and geographical statistics pertaining to Indus- 
try dollar sales, Labels issued, Handbags Put in Work, Average 
Member of Employees, Irunber of Hours worked and Wages Paid, during 
the period ended February 28, 1935 nay be found in the audit re- 
ports of 'Homos and Davis in the Code Authorities Accounts Section 
files. 

A partial summary for the period from June 10, 1934 
to February 23, 1935 follows: 



Area I Tet Sa les .1e-oorted(*) Labels Issued Handbags Put 

■ — . ^ > ^ 

Amount fo Ho. Jo in Work 

lieu York City $12,091,814 42.95 9,556,000 33.70 7,475,610 



lieu England 


5 


,642, 


,972 


20.03 


6 


,391,125 22.54 


5,073,142 


Middle Atlantic 


7 


,980, 


,718 


28.33 


10 


,737,700 37.87 


9,123,261 


Southern 




637. 


,355 


2.26 




436,500 1.54 


292,002 


Ilid-Western 


1 


,558, 


.394 


5.53 


1 


,069,375 3.77 


315,892 


Western 




254. 


645 


.92 




164,000 .58 


99,631 



$28,166,898 lOO.OCfj 28,354,700 100.00^22,879,538 

(*) The number of manufactures reporting sales during the period 
varied as follous: 

Period Reports Received 

harch 26 to April 30, 1934 267 

hoy, 1934 273 

June, 1934 272 

July, 1934 282 

August, 1934 302 

Sept . , 1934 311 

October, 1934 303 

hovenber, 1934 291 

December, 1934 271 

January, 1935 193 

February, 1935 3 

Following the Supreme Court decision in the Schechter 
case rendered on hay 27, 1935, there uas strong evidence of the 
desire ';of members of this Industry to continue the Fair Trade 
Practice provisions of the Code. There continued application to 



9311 



-455- 

the Code Authority for the issuance of ERA labels and an unreport- 
ed nunber of labels, it was understood, were thereafter supplied 
to applicants risking such voluntas applications. 

Current press reports indicate a meeting of a general 
committee of the Vomen' s Handbag Inc.ustry, to adopt a voluntary 
Code agreement, rill be held on June 24, 1935, to be followed by 
an Industry wide gathering on June 25, 1935, to approve the 
Committee's plan. Lir. A. i'.ittenthal, Executive Director of the 
former Ladies' Handbag Code Authority , is reported to have said 
that firms representing more than 85;j of the sales volume of the 
Industry have agreed to the adoption of such an agreement upon the 
committee's' • approval. The plan aims to continue the same code 
wcges, hours and fair trade practice rules. A bureau for the 
registration of designs will be an added feature. The agreement 
also "ill call for the use of a "security label" that will serve 
as a symbol to retailers and consumers that the manufacture^ is 
complying with wage and hour standards, is not employing child 
labor and is abiding by the fair trade rules. 

(Signed) A.. A. Fisher 

A. A. Fisher 
Assistant Deputy 



3811 



-456- 



EXHIBIT Z 

Excerpts from Code Authority 
Minutes and brief in re Price Groupings 



9811 



-457- 
EXHIBIT "Z" 



CODE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

MEETING NO. 18 

HOTEL McALPIN - AUGUST 2, 1934 - 6:30 P. M. 

(EXCERPT OF MINUTES) 

Code Director, A. Mittenthal, rendered a report on Price Groupings. 
(Report attached) Exhibit E 



It was duly moved "by Mr. G. Meyers and duly seconded by 
Mr. M. Warschauer, that the Code Authority go on record 
in favor of -orice groupings, and that a committee take 
the matter un with the retailers, and report back to the 
Code Authority. Carried. 

Reuort rendered on Committee to Study Existing Conditions 
in the Industry. Code Director, A. Mittenthal, presented 
the following resolution for adoption: (Exhibit F attached) 

RESyLVED that the Code of Fair Competition for the 
Ladies' Handbag Industry be amended by 
inserting a trade practice rule which 
shall be known as Section 16 of Article VIII 
to read as follows: 

"Nc member of the industry shall repair bags 
without making a reasonable charge for such 
repairs, when such bags show that they have 
been in use. No member of the industry shall 
pay any forwarding charges for such repairs." 

It was duly moved. by Mr. S. Mutterperl and duly seconded by 
Mr. M. H. Blumenfeld that this resolution be arroroved. 
Carried. 

Meeting adjourned at 11:30 P. M. 

I hereby certify tnat the above minutes are a true 
record. 

/s/ Irving Schoenholz 

Secretary 



9811 



-453- 
REPORT ON PRICE GROUPINGS 



The matter of t>rice groupings was discussed with the Deputy 
Administrator in Washington, and also with the Legal Division. It is 
suggested by the Deputy Administrator that the Code Authority ask to 
have the Code amended so as to include the following section: 

"Wholesale Prices. .... To maintain established trade "prac- 
tice, and to limit the multiplication of numbers, but 
without any attempt at price fixing, each person being 
free to determine the value to be given at each price, 
the following shall be the wholesale prices, per dozen, 
for sale to retailers, and no intermediate -orices may be 
used. " 

It will also be necessary to insert into this section the 
list of prices to be included in this price grouping. If the Code 
Authority feels that it is important to have price grouping in the 
Code, they should act on this amendment a.t once. 



PRICE GROUPINGS 



The fixing of a price range by a manufacturer does not in any 
way mean the fixing of prices in the sense that it destroys compe- 
tition. There are no two manufacturers who make identical bags, 
either in style or materials or in exact value. A price range set 
by a manufacturer for his product is absolutely necessary to such 
manufacturer, particularly those with limited capital and small 
production. 

It is for these reasons the industry, during the past five years, 
has become highly specialized as to a particular price range. The 
largest number of manufacturers make either one or two price ranges. 

The largest volume of business in the industry is had by those 
who manufacture bags to wholesale at $7.75 a dozen only, and 315.75 
a dozen only, and &22.50 a dozen only. They give the best value 
possible at the limit of price that the retailer will pay for a bag 
to retail at $1.00, Si. 95, or $2.95 respectively. With every manu- 
facturer competing on these price levels competition is based en- 
tirely upon value and style. The industry is a highly styled one, 
and the manufacturer who guesses wrong on style, color or material, 
suffers a loss regardless of the amount of intrinsic value in the bag. 

To produce a finished handbag reauires the assembling of from ten 
to twenty different materials, and the processing reauires about twenty 
distinct operations. It is important that the Ladies' Handbag Industry 
be permitted to have price groupings at which price groupings manufac- 
turers will compete on a basis of style, duality and value. Such price 
groupings shall be maintained by all manufacturers in the industry. 

9311 



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■7 ?•.:>•; in 



-460- 

The retailer, even if he is not inclined to buy the line that 
has been quoted at $7.50 a dozen cr sometimes at $7.25 a dozen, uses 
these prices nevertheless to break down the price lines quoted at 
$7.75 a dozen. The quoting of a price cf $7.50 a dozen or $7.25 a 
dozen by this small number cf manufacturers, creates a price war 
between the manufacturers. The lower prices must soon be met by 
other manufacturers. The price of $7.75 a dozen, at which price 
fifty manufacturers have built their lines, in which they are giving 
the best value they can afford to give with only a minimum of profit 
added, is immediately destroyed. 

If ' these manufacturers continue tc sell the same lines at the 
lower prices they built to sell at $7.75 a dozen, the difference in 
prices usually is enough to offset their margin of profit. If they 
discard their lines and make uo new lines to meet the lower -orice levels, 
they must do so at a complete loss of their investment in time, materials 
and labor. The chances are, after they have made utj the new lines to 
meet the lower price levels, the manufacturers who are engaged in this 
price war competition will again lower their prices. The whole -oractice 
is a vicious one, with the net result that neither manufacturers nor 
retailers make a profit. The large number of failures amongst the manu- 
facturers in the industry each year will bear evidence of the results 
of this destructive price competition. 

Price groupings will establish -orice levels, and prevent destruc- 
tion of profits in the industry. 



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EXHIBIT A-l 
Virginia Art Studios 



9811 



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1 larch 30, 1934 



Mr. James C. Worthy, 
Assistant Deputy Administrator, 
National Recovery Administration, 
Washington, D. C. 

Dear Sir: 

I am advised "by the Virginia Art Goods Studios, Inc., located in 
this city, that acting upon Executive Order #2, of July 15, 1933, 
whereby -privilege is given all persons or corporations to petition for 
exception to, exemption from or modification of any Code of Pair 
Competition which materially affects said -persons or corporations, in 
which said persons or corporations have had no -part in forming either 
in person or by representation, they will file a petition for modifica- 
tion of certain provisions and conditions set forth in the Code for the 
Ladies Hand-Bag Industry, approved Code #332. 

In all fairness and justice the Lynchburg Chamber of Commerce 
earnestly hones that this concern will be granted a hearing in this 
matter. They were not re-presented when the final code was adopted, 
and know nothing of its final provisions. I have studied this Code 
carefully, and feel that it will work an undue hardship on this concern. 
Lynchburg is an industrial center, and practically every industry is 
now operating under its permanent code. In our shoe factories, textile 
mills, garment factories, hosiery mills and practically all others, the 
minimum -age of 30 cents per hour for a 40 hour week, or $12.00 a week, 
is fixed. Identically the same class of labor is used in the hand bag 
establishment as in the other industries and it grossly unfair to them 
that they should be compelled to pay a minimum wage of $14.00 per week 
as against $12.00 per week minimum existing in all the other industries 
in the city. The other industries in Lynchburg are operating under 
codes in which labor differentials are allowed, because of their 
southern location, but no such differential is allowed in the Hand-Bag 
Code. The codes of all the other industries in the city allow a 
differential for apprentices and learners of at least 80$ of the wage, 
whereas the Hand-Bag Code makes no such provision. 

I am thoroughly acquainted with the nature of the business of this 
hand-bag establishment, and I know that they operate on a very narrow 
margin of -profit. If they are compelled to -pay the wages prescribed 
in their Code, I firmly believe it will result in their being forced 
out of business. They are only a small establishment as far as the 
industry is concerned, and have continued in business only by overcoming 
tremendous handicaps. 

They will petition for a minimum wage of 30 cents per hour for 
a 40 hour week, and for a wage of 8<jfo of this minimum for apprentices 
for a period of at least six or eight weeks. I think this request to 
be eminently fair, and will only be giving to them the same rights and 
privileges allowed under the various codes to all the other industries 
in the city. May I express the hope that the petition of this concern 

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for a hearing will "be readily granted, as I an sure that the facts in 
the case will warrant? 

Very truly yours, 

(Signed) R. D.R. 

Robert D. Ramsey, 
Business Manager. 

Copy to 

The Virginia Art Goods Studios, Inc., 

Lynchburg, Va. 



STATE OF VIRGINIA, 

To-tfit: 
CITY OF LYNCHBURG, 

* # 

I Mamie E. Rohr, do hereby make affidavit as follows: 

1. I am President -of -Virginia Art Goods Studios, Incorporated, 
a corporation organized under the laws of the State of 
Virginia, and engaged in the manufacture and, sale of ladies' 
handbags. « 

2. I havevbeen President of said corporation since its 
organization, and have personal knowledge of the facts 
herein set forth. 

3. That said Corporation has complied with all tho nrovisions 
of the Code of Fair Competition for the Ladies' Handbag 

'Industry, except as to its provisions relating to labor, 
as to which particular provisions it has been, and is, 
operating under an exemption order, expiring September 1, 1934; 
and that it' has complied with all the provisions and conditions 
of said exemption order. 

4. That it is essential to the interests of said Corporation that 
said period of exemption be extended to such time as the 
peculiar situation- of said Corooration, and the few others in 
like situation, may be appropriately -orovided for by amendments 
to the said Code which have been, or in due course will be, 
presented for consideration. 

5. That the existing provisions of said Code relating to labor 
work undue hardship upon said Corporation for the following 
reasons: 

(a) The business in which it is engaged is highly 

competitive. There are many such manufacturers in 
the northern states, where the business has been an 
established one for many years; and where the skilled 
labor required is plentiful and easy to secure, and 
is able to turn out finished products in a volume and 
with a speed which can be equalled only equally 
skilled and experienced labor. 

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(b) The Virginia Art Goods Studios, Incorporated, is 

a pioneer in its locality. Its factory is located 
in Lynchburg, Virginia, where the reauisite skilled 
labor is comparatively scarce, and has to be trained. 
And even when locally trained, the available labor 
is unable to compare with that in northern factories, 
in the volume and speed of production. 

(c) The practical and inevitable result is that the 
Virginia Art Goods Studios', Incorporated, cannot 
successfully compete with other manufacturers whose ' 
output per capita of enroloyees is so much greater. 

(d) An analysis of the oooks of Virginia Art Goods 
Studios, Incoroorated, discloses that during a typical 
t^o-weeks period in September, 1933, the Company's 
production and sale cost, exclusive of officers 1 
salaries and overhead, -'as $10,321.12. The sale price 

. of the -products so produced was $12,205.50, showing a 
substantial loss when salaries and overhead are taken 
into account. Upon its fall operations in 1933 our 
Company sustained a loss of $11,000.00. During that' 
period our Company operated under a wage scale which 
was a 204 increase over that previously obtaining, 
accomplished by reduction of hours of labor from 48 
to 40 per week. 

Every reasonable endeavor has been made to increase 
production by proper methods, but the wage scale provided 
in- the Code gives little prospect of profitable operation. 

During the first two weeks of August, 1934, the sale 
value of the Company's products was $6,550.00, the 
production and sale cost thereof, not including salaries 
and overhead, was $4,853.47, still indicating an actual 
loss. 

Tests made in our factory by our production manager, 
who has had experience in northern factories, indicate 
that the volume of production in our factory 'oy 
employees available in our section, is approximately 
70$ of that in northern factories, due to difference in 
■• the efficiency of our employees in comparison. 

Although the prices of our products have left no margin 
of profit, as p.bove set forth, they are higher than those 
of northern manufacturers for similar products. Therefore 
it is obvious that the selling price cannot be increased. 
The only source of relief would seem to be a more 
eouitable wage scale for our territory. 

The Virginia Art Goods Studios has been enabled to 
continue in operation because of its ownership of patents 
on a spring line of ladies' bags which it has been able 
to manufacture in volume and sell at a reasonable profit. 



9811 



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-465- 

But recently there have "been infringements of its 
patents, and cheap imitations of its exclusive 
products, which have materially affected its 
"business, and will most probably "be more disastrous 
in future rending delays and difficulties of 
litigation looking to our "protection. 

In view of this 'situation losses sustained in the 
fall cannot be counter-balanced as heretofore by 
profits on spring business, which is further evidence 
of the need of a lower wage scale for our industry, 
which v, ould not ,_ rork a hardship on our employees in 
view of the lower cost of living in the south. 

(e) There are many expenses, including taxes, licenses, 
rent, wo-er, light and heft, ^hich are common to all 
industrial concerns in its locality; and yet the 
Virginia Art Goods Studios, Incorporated, is-reauired • 
under the Code for its Industry, to pay a higher 
minimum wage than any other industry in its locality, 
even under the respective" Codes for such other 
industries, thus placing said Company at a marked 
disadvantage with such other local industrial concerns. 

6. There are very few, certainly not exceeding half a dozen 
concerns or establishments 'engaged in the manufacture of 
ladies' handbags in all the southern states. Those few 
are striving to develop the industry in their respective 
territories and to provide employment for labor now 
unemployed. But unless accorded a proper differential as 
to wages to be paid their empl'oyees, : they will be so , 
seriously handicapped in their efforts- that they will not 
be able to maintain thenlselves on a fairly profitable basis, 
in competition with more fortunately situated competitors. 

7. It is necessary, in the business of the Virginia Art Goods 
Studios, Incorporated, to employ at all times a number of 
unskilled apprentices or learners, who are inefficient and 
not profitably productive during such period of training, at 
this wage scale fixed by the Code. And this materially 
increases the disadvantage of 'its situation, as a com- 
petitor of concerns which are not compelled to use such 
untrained labor to a like extent. 

8. This affidavit is made for the purpose of filing the same 
with the Administrator in support of the petition of the 
Virginia Art Goods Studios, Licorporated, praying an exten- 
sion of the period during which it may be exempted from the 
labor provisions of the Code of Fair Competition for the 
Ladies' Handbag Industry. ; 

9. A copy of said petition with its accompanying documents, has 



9811 



-466- 

teen forwarded to Code Authority, Ladies' Handbag Industry, 
347 Fifth Avenue, Hew York. 

/s/ Mamie E. Rohr 

Subscribed and sworn to oe-fore rae this 25th day of August, 1934, 

WITNESS ray hand and Notarial' seal. 

/s/ Emma D. Ambrose 
Notary Public 

(SEAL) ' My commission expires Sept. 4, 1934. 

STATE OP VIRGINIA, 

To-»/it: 
CITY CP LYNCHBURG, 

I, 0. H. Tufts, do hereby make the_ following affidavit: 

1. I am a Certified Public Accountant, residing and doing 
business in the City of Lynchburg, Va. 

2. I audited the books of the Virginia Art Goods Studios, In- 
corporated,, covering its operations for 1933. 

3. I have read the affidavit of Mamie E. Rohr made to be filed 
in support of petition of said Corporation for an extension 
of the period of exemption from the labor provisions of the 
Code adopted for its industry, and h-^ve checked the figures 
therein set forth for operations during a portion of 
September, 1933, and August, 1934. I find them in agreement 
with the cost record kept.. My audit for 1933 shows actual 
cost slightly in excess of cost records. The $11,000.00 
loss on its business during the fall of 1933 is correct and 
in agreement with ray audit report. 

Isl 0. H. Tufts 

Subscribed and sworn to before; rae this 25th day of August, 1934. 

Witness ray hand and Notarial .seal. 

/s/ Emma D, Ambrose 
Notary Public 

SEAL My comnission expires Sept. 4, 1934 

STATE OP VIRGINIA, 

To-Vit: 

CITY OF LYNCHBURG, . . i 

I Edmund Valtuck, do hereby make affidavit as follows: 
9811 



-457-. 

1. I have had many years of experience as designer, 
superintendent of labor, and production manager, in 
factories engaged in the .manufacture of ladies* handbags, 
in northern states; and am now Production Manager for 
Virginia Art Goods Studios, Incorporated, at. its factory 
in Lynchburg, Va. 

2. In the northern states, where the ladies' handbag 
industry has been established for many -'ears, there is 
at all times an available supply of skilled labor suit- 
able to the needs of the several manufacturers. 

3. In Virginia there is no such ready supply of skilled labor, 
and in the Lynchburg factory of the Virginia Art Goods 
Studios there is always need for' a number. of learners in 
training who are not probitable producers during their 
period of training, which is usually about eight or ten 
weeks. " 

4. The available labor in Virginia, even -after training, is 

not able to turn out the same volume of production per capita 
of employees as the sane type of labor in northern factories. 
This is due to tempermental, racial and community differences, 
which are likely to continue to exist for many years. 

5. ■ Tests "that -I .have made in the Lynchburg factory disclose 

that the volume of production by the regular employees 
available is only about 70$ of that secured in northern 
factories under similar conditions. ■ 

/s/ Edmund Waltuck 

Subscribed and sworn to before me this 25th day of 
August, 1934. 

WITNESS MY HAND AND NOTARIAL SEAli 

/s/ Emma D. Ambrose 
(SEAL) Notary Public 



May 11, 1934 

In reply refer to Division 5. 

Miss Mamie E. Rohr, President, 
The Virginia- Art Goods Studios, Inc., 
1306 Church Street, ' , • , . 
Lynchburg, Va. 

Dear Miss Rohr: .'.■"■■■■ 

I have been studying the files or correspondence on your applica- 
tion for an exemption and modification of the Code of Fair Competition 
for the Ladies Handbag Industry. 

9811 



-468- 

As you are^ aware, a Hearing was held on a number of other 
applications' for execration May 7, at which time your petitions and 
correspondence ••'ere read into the records. Before making' any final 
decision, however, it will be necessary for us to have much more :and 
complete information on your peculiar problens than we now have. I 
should appreciate your submitting to ne as quickly as -possible, the 
following data: •' 

(1) The amount "of business done in the year 1933 in bags made of re.al 
leather; 

(2) The amount - of business done in 1933 in bags made of imitation 
leather; 

(3) The amount of business done in the year 1933 in bags made of 
fabrics nnd other materials; 

(4) Do the same workers work on all three types of bags? ' 

(5) How many workers were employed in the peak of your season in 
1933? 

(6) How many were employed during- the lowest point of your season in 
1933? 

(7) On what basis are your workers compensated? (I.E., piece work, 
hour work, or week work) 

(8) Classify your employees according to operation performed, stating 
hourly compensation of each. 

(9) In which price ranges are your goods sold? 

(10) Since the adoption of the Code, has there been any change in 
these price ranges? If so, what? 

(11) What percentage of the wholesale price of your products is 
represented by direct labor costs? 

(12J What percentage of your wholesale price is represented by selling 
costs? 

(13) What oercentage of your wholesale price is represented by 
administrative and general overhead costs? 

1 

(14) What are your regular 'dhannels of distribution, (i.e., wholesale, 
direct sales to retailers, etc., etc.) 

(15) Do your products enjoy a national-wide distribution? If not, in 
which areas do you make your biggest sales?,. 

(16) Give me the names and addresses of your most direct competitors. 

Upon T-eceiot of the aoove- information, I shall be in a much better 
position to judge your case. 

Very truly yours, 



James C. Jorthy 



-469- 

NATIQITAL RECOVERY ADMI1TISTRATI01T 

Washington, D. C. 

MEMORANDUM June 1, 1934 

To: Miss Robinson 

From: Mr. Farnsworth 

Subject: Virginia Art Goods Studio, Inc. 

The Virginia Art Studios filed with the Administration a petition 
for exemption from certain provisions of the Ladies Handbag Code 
pursuant" to the terms of the Executive Order of July 15, These people, 
I understand, had one or more conferences with Mr. Rosenblatt, with 
the result that Mr. Rosenblatt informed them that it -rould be unnecessary 
for them to atroear at the Public Herring, and that the filing of 
briefs would be sufficient. 

The Hearing was held on a number of other similar -oetitions on 
May 7, and at that time the briefs filed ay this concern were entered 
into the record. These oriefr, conti ined much necessary information, 
but most of it was of a more or less general sort. Before rendering 
a final decision on the matter, certain other information was quite 
necessary." If the petitioner had been present at the Hearing, this 
information could have been elicited by direct mj.es tioning. Since 
this is not the case, it was necessary to secure it by corresoondence. 

Attached herewith is a copy of the letter, dated i*iay 11, sent 
to this firm requesting further information. To date no acknowledgment 
of this has been received. 

I understand that these oeonle object to this Questionnaire on 
the ground that it would reouire a two weeks investigation by a 
certified oublic accountant. A study of these questions, I think, will 
show that this is not entirely the ca.se. It is sufficient to answer 
the first three questions by means of aooroximations. Questions 4 
through 10 certainly do not require the assistance of an accountant. 
A quick glance at payroll records would be sufficient' to answer all of 
them. 

The most important Questions are ilos. 11, 12, and 13; for these 
a fairly exact answer is necessary, and it is conceivable that advices 
of an accountant might be necessary. Host firms, however, secure these 
figures in the ordinary course of business management. 

Questions 14, 15, and 16, of course, do not require the assistances 
of an accountant. 

/s/ W. P. F. 
Vim. P. Farnsworth 



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-470- 

June 12, 1934 

The Honorable Carter Glass 
United States Senate 
Washington, D. C. 

My dear Senator Glass: 

I send you herewith cony of a letter dated May 11, addressed to 
Miss Mamie E. Rohr, President. The Virginia Art Goods Studios, Inc., 
1306 Church Street, Lynchburg, Virginia, petitioners for exemption of 
the provisions of the Ladies Handbag Manufacturing Code. I also send 
you a summary of the status of this petition. 

As I am very, anxious to do whatever I c»n for Miss Rohr, could 
you assist me in having the petitioners submit the information requested 
so that the petition, if granted, will be based uoon facts in our 
possession, and in accordance with Administration requirements. 

Sincerely, 

(signed) SOL A. ?:0SE':T3LATT 

Division Administrator 



CODE AUTHORITY 
LADIES' HAHDBAG LIDUSTRY 
347 'Fifth Avenue 
Hew York 



July 3, 1934 

Mr. David Barr 

Assistant Deputy Administrator 
Department of Commerce Building 
Washington, D. C. 

Dear Mr. Barr: 

We are in receipt of your letter of June 29, 1934 in reference 
to the Virginia Art Goods 'Studios. The records of this case in the 
Administration files should show the following: 

This firm did make application to the Administration for exception 
to the Code within the ten days following approval of the Code,, How- 
ever, it was proved that this firm was a member of the Associated 
Handbag Industries at the time the Code was approved, and since the 
Associated Handbag Industries of America was the sponsor of the Code, 
the Virginia Art Goods Studios were assentors to the Code. 

In view of this information furnished ay the Code Authority, the 
Virginia Art Goods Studios were notified that they were not entitled 

9811 



-471- 

to a hearing. This is the last that -e heard of the case, and we 
therefore took it for granted thrt no exception to the Code has ever 
"been granted to this firm. 

if you desire our files for the purpose of ascertaining these facts, 
we shall he able to supply them to you. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG IHEfUSTRY 

(Signed) A. Mittenthal 
A. Kit tenths! 

AM: AS Code Director 



HEARIITG CALLED Oil PET I TI OH FOR 

EXEMPTION BY VIRGINIA ART STUDIOS 

TO '.AGE PROVISION, LADIES' HANDBAG 

CODE, JULY 27, 1934. 

The following '-'ere present: 

Leigh E. Ore, Assistant Deputy Administrator, conducting the 
hearing 

Kiss Rohr, Virginia Art Studios 

Mr. Taylor, Industrial Advisory Board 

Miss Schneiderman, Labor Advisory Board 

David Barr, Assistant Deouty Administrator 

Harry S. Berry, Deputy Administrator 

Mr. Mittenthal, Code Director 

Mr. Berkowitz, Code Director 

Mr. Ore, opening the hearing, asked for a brief statement of the 
case from Miss Rohr. 

MISS ROHR: We began working under the President's Reemployment 
Agreement at its inception and lived up to it. In doing that the 
Virginia Art Studios lost $11,000 in the fall. We make slip cover 
bags, and if it were not for that r 'e could not have stayed in business. 
In the spring we made enough to stand the loss. My sister wanted to 
go out of business in the fall, but we could not do that because too 
many people were dependent on us for work. We went ahead in spite of 
the fact we '-ere losing. When the Handbag Code was up for discussion 
in New York the things we are asking for exemption on are just what was 
discussed and passed on. After that, the Code was changed without our 
knowing it.- When it was formally passed the minimum wage was raised and 
the apprentice period left out. 

MR. ORE: Mr. Mittenthal, do you have any knowledge, on record which 

9311 



-472- ' 

would show whether or not the notice of the public hearing on the 
Ladies' Handbag Code was sent to the Virginia Art Studios? 

■MR. MITTE1TTHAL: Every known member of the industry was notified, 

MR. ORE: You know of the public hearing? 

MISS ROHR: Yes, and I did not appear hut wrote to Mr. Glass and 
filed a petition. 

MR. BARR: On the basis of that evidence, the petitioner is not 
entitled to an exemption under the July 15 order. They participated in 
the writing of the Code. 

MISS ROHR: But the Code I participated in I was willing to live 
up to. I know nothing about the other one. 

MR. BARR; The industry agreed to submit a certain Code. When it 
came to public hearing the aporoved code was the same, 

MISS ROHR: We had no southern representative. 

MR. ORE: I think we can waiVe that oossible technicality. Do 
you belong to the Association? 

MISS ROHR: We did not want to belong to the Ladies' Handbag 
Association, : 

MR. ORE: She did not assent to the code of 35<£ an hour but 206 
an hour. 

MISS ROHR: And as the code was presented to us there was an 
apprentice cl~use. '■ * 

MR. MITTEHTHAL: At the meeting of the Association there was a 
proposal for an apprentice clause which did not become a part of the 
Code. The rate of 2>0<p an hour at that time was opposed by the Labor 
Board as being inadequate, and it was made 35rf an hour for all sections 
of the country and it was aporoved, 

: MR, ORE: Will you state your viewpoint for the benefit of the 
record — your attitude in relation to this exemption? ' 

MR. MITTE'UTHAL: It is my understanding that Miss Rohr had received 
a letter from the Deputy Administrator and that she thereupon paid a 
visit to Deputy Administrator Howard. Miss Rohr again visited the 
office and after tnat visit said she had not received any satisfaction. 

MISS ROHR: The first letter stated '~ r e would be given a hearing. 
Then we had a letter of refusal saying we did not participate. That 
letter was not answered. ' 

MR. MITTEIJTHAL: The Code Authority acted upon the petition after 
a thorough study of it and the conditions surrounding that particular 
factory. They voted the problem of the Virginia Art -Studios was no 

9811 



-473- 

different than that of perhaps 100 other firms located outside of 

New York operating under the same or similar conditions, and therefore 

refused the petition. 

MISS ROHR: I was not notified. 

MR. MITTENTHAL: That was sent to the Administrator. It was then 
our understanding the Administration held a hearing in which the cr>se of 
the Virginia Art Studios was one of the cases to he heard.' At this 
hearing the Virginia Art Studios did not put in an appearance. 

MISS ROHR: Mr. Howard pnd Mr. Rosenblatt told us we did not need 
to come. I was sorry they did not give us the henefit of coming. My 
sister and I cane a few days before hut we could not see Mr. Howard. 

COLONEL BERRY: I understand an exemption is of only a temporary 
nature. If conditions are such as to warrant a permanent exemption 
there will he an amendment to the code. Any party can file an amendment. 
I think you should follow that method. It is my understanding from a 
talk with the Division Administration that NRA policy would require a 
4~)<p minimum wage and a 40 hour week. We have that 'in the Leather Code. 
Ve are going to take that tip with the other codes in this section. 

MISS CHNEIDERilAN: Instead of 30 and 35 it will be 40? 

COLONEL BERRG-1 Yes. In leather, Boot and Shoe, Saddlery and 
Luggage. That is as far as I know. I do not think this lady can expect 
to get a permanent exemption and that is the only kind that would give 
any relief. My suggestion is to bring up amendments to this code, 
which is her privilege. The proper course is to propose these amend- 
ments and bring them out for discussion. 

MISS ROHR: It is not our policy to underpay our people. They 
feel sure we are going to give them all we can. All we want is to make 
a fair profit and give the rest hack to our employees. 

COLONEL BERRY: That is beyond the province of NRA. : 

MR. ORE: What Colonel Berry says is true. But "'e must submit 
all evidence to suoport this petition for either approval of denial by 
the Division Administrator. 

COLONEL BERRY: What period of tine do you want? 

MISS ROHR: Ve asked for on apprentice period from six to eight 
weeks. 

COLONEL BERRY: What will that save you? 

MISS ROHR: We asked -for SCKo of the minimum. 

COLONEL BERRY: You save 7(£ an hour or $2.80 a week over a 6 weeks 
period. That would be less than $15 per employee. That would not be 
a material help. 



9811 



_474~ 

-■ MISS ROHR: _ We ask for a 50^ minimum. 

MR. MITT3LTTHAL: As reflecting the attitude of the Code Authority, 
in order to pass upon the petition of the Virginia Art Studios we wrote 
to them requesting information and statistics of their business and we 
failed to receive any reply. We also were told by. the Administration 
' they had requested certain facts which they did not 'obtain. 

MISS. ROHR: I think I can explain that. I have already said what 
hanpenod. We hated very much to give the facts of our business out where 
they would be seen. We knew that committee was made up of competitors 
and we. cannot comoete with those in Hew York. Vie sent that list of ques- 
tions to Mr, Glass and asked him if he would see General Johnson and see 
what he could do for us iii the way of getting an exemption. Just what 
Mr. Glass did I do not know, but I know he got in touch with General 
Johnson and he wrote us a letter saying General Johnson said it was all 
right for us to proceed as we -'era. 

MR. ORE: General Johnson was handling it in the regular manner of 
granting a stay. Evidently your petition was filed with this Administra- 
tion within ten days after annroval of the code, 

MISS RCOl: That is not what Mr. Glass wrote, that lie said. 

MR. ORE: Regardless of that the Code Authority, is anroved by 
the Government and it is not optional with them. The figures they ob- 
tain are confidential and not to be given to other members of the in- 
dustry. There two men act as Code Directors, and I have every reason 
to, believe tneir work is kept confidential. Witnout facts iii the record 
on which to base your petition for exception they had nothing else to 
do but to say they could not grant you an e;:ce;-tion. You have been 
stayed. You. are operating under a stay now — I believe a bit irregular, 
but the Administrator has been fit to overlook the technicality and 
permit you to operate under a stay and you. are now paying your em- 
ployees the minimum of $12 a v/eek. 

MISS ROKR: Very few of them get that little. 

MR. ORE: The hour provisions are satisfactory. As Colonel Berry 
told you, all of these codes are to be reopened and brought into line 
rath the policy of the Administration at 40^ an hour — the suggestion 
of the Labor Advisory 3oard. In order to handle your c?se in the re- 
gular manner we are giving you this hearing and the Industrial Adviser 
and the Labor Adviser are present. It was not necessary, to bring in 
the other boards, but we are giving all representatives a chance to 
put their statements into the z-ecord. 



17 



COLOKEL BERRY: Mr. 3arr, have you expresc-ed your ideas? 

MR. BA?R: l!o. I am not familiar with your idea outlined before. 
I asked for the questionnaire and never received it and I have no actual 
facts uion which to base any conclusion. The first I knew this 
petitioner emnloys as many people as they do was yesterday. I thought it 



-475- 

a small concern with a limited production and if the code wage raised the 
wages of the vast majority of their small number of employees it was 
like other petitions we received. But I found today they employ over 
160 people. 

MISS ROHR: Hot all of the year. Just in the spring when we make 
slip covers and that is not handbag work. 

MR. BARR: From my experience with other members of the industry 
it is considered a large member of the industry. Their gross .is ov.r 
$250,000 a year. In the peak they employ about 160 and in the dff 
season about 80, and very few of the employees get $12. They have an 
off-ice in New York and sell in Hew York in competition with other manu- 
facturers. I do not see any merit in .the petition, out Miss Rohr 1ms 
not finished her testimony and other facts may be brought oixt. 

COLONEL BERRY: For what period did she ask exemption? 

MR. BARR: Just under the Executive Order. 

COLONEL BERRY: Is the stay now in force? 

MR. BARR: That is correct. We are holding this hearing for 
the propose of terminating this stay. 

MR. ORB: I think Mr. Taylor has a statement. 

MR. TAYLOR: The Industrial Advisory Board has believed from the 
beginning in such differentials in many industries to take care of 
certain situations- that arise. Whether the Board would take that 
position on this case or not I am not sure. I think we should have 
further development of the facts, particularly those facts which 
might indicate this class is less efficient or productive than labor 
in New York. 

MR. BARR: The situation here is this. While the industry is 

common in Hew York, it is now 80 ; 3 of it in 'small cities around New York. 

The a vai lability of workers is about the same in any industrial center. 

Most e-f these manufacturers are in small towns outside of Hew York, in 

Rochester, New Jersey small towns, and Connect icut in which they have 

to rely upon fairly unskilled workers in the beginning so there is 

nothing -particularly uncommon -about Virginia Art Studios. 

- t 

COLONEL BERRY: This exemption Was granted how long since. 

MR BARR: There was question about it. About a week or ten days 
ago this matter came up again, and I was directed to dray/ up an order 
granting a petition. While this was in the working' Colonel Lynch called 
me in and then Mr. Ore called this morning. 

COLONEL 3ERRY: These gentlemen ?re goin^ to pro ose your amendment. 
When will you bo able to get them together?' 

MR. MITTEHTHAL: The next meeting of the Code Authority is Thurs- 
day.- We have a meeting every two weeks. 

9811 



-475- ' 

COLONEL BSRRY: We will have to have a hearing on these amendments 
"before the end of August. The Labor Advisory Board will have some amend- 
ments. Do yo\i see any objections to permitting this order- to ; go into 
effect and remain in effect until the first of September, provided the 
petitioner desires to present an amendment to the coce involved to get 
a differential? ■ '■ ■. '. : 

MR. ORE: In that connection, Colonel Lynch said to hold a hearing 
and act upon the s;tay. She. has not a formal 'vetiti-vn for an exemption 
before the Administrator now., ' She is operating under a stay. The Adminis- 
trator was of the same mind that there were -only a few people .involved. 
After the case has been settled on its merit or at any time, any interes- 
ted party has a right to file a petition for amendment to the Code with 
the Code Authority. Even though the Code Authority may deny it, "they 
are duty bound to turn it over to the Administration. 

COLONEL BERRY: If the differential question is vital: to this, 
there would be no objection to making a petition to the Administration 
that this stay not be terminated until September 1. 

MR. TAYLOR: Terminate the stay and grant a S weeks temporary 
exemption. 

MR. BARR: If the stay is terminated as the result of this hear- 
ing and the exemption granted under, the order of July 15, it should be 
extended to those similarly situated. 

COLONEL BERRY: We do not know yet the situation for each member 
of the industry would have to file an individual petition. 

MR. MITTSNTHAL: The Virginia' Art Studios is one of the most 
highly regarded firms in the industry. Their "easiness tactics are of 
the very highest, and anything that Miss Rohr says with respect to this 
case is exactly as she states. The problem?. that is presented to the 
industry because of the position taken by the Virginia Art Studios is 
one of .grave moment to the industry. As it has been stated heite, she '.'. 
is competing with manufacturers in other parts of the country and in 
Hew York and is able to maintain a good volume of business and I under- 
stand the firm is one of the best rated firms in the industry. The 
Code Authority is very much interested and concerned in the outcome of 
this case. We have had petitions from firms as far south as Miami., 
Florida, and there were no exemptions granted in any of the other cases 
that have come before the Code Authority. 

MR. 3A2R: You mean the Code Authority has never recommended any. 

MR. MITTSHTHAL: Yes. I think some explanation is due the Code 
Authority as to why the Virginia Art Studios has oesn operating under a 
stay without any knowledge of the -Code Authority. It was our understand- 
ing that failure to appear at the hearing was at that time. 
We received no notice of it. We received a letter from the Virginia Art 
Studios they would use labels of the Code Authority provided the Code 



QR11 



-477- 

Authority did agree to the wage scale they had set for themselves and 
the apprentice clause under which they were operating. The Code Authority 
denied that request and a letter was written to the Virginia Art 
Studios stated the position of the Code Authority and cited them for 
non-compliance on facts in their letter and stated restitution would 
he required from March 2G, and until restitution was made no labels 
would he issued. We received no reply to that letter written on 
July 5. Whatever is done in this case, I am impartial, Five hundred 
manufacturers are involved. A few hundred are vitally interested in 
the outcome, and whatever is done must be done in consideration of 
500 manufacturers who are operating under the code, 

MISS SCHNEIDSRMAN: • The Labor Advisory Board is opposed to any 
kind of territorial differential. Not voting against the Cotton 
Textile differential that was granted in the first code, we realize 
was a bad precedent to set. However, the excuse in the Cotton 
Textile differential was that there always existed a differential 
between the South and North and they were providing housing conditions 
at so low a rate that it almost made up for the differential in the 
code. Since that time it seems that any code that has no differen- 
tial comes to the point where the southern manufacturers ask for it. 
The minimum rate is the minimum for the lowest type of employment, 
and in the factories in the North a very small percentage of the 
workers- work on the minimum. The larger percentage are above the 
minimum, Pbcketbook making is a skilled industry. I have not known 
about this case until I entered your office, Mr. Ore. so that I have 
no way of knowing the number of workers. In a way I think the whole 
thing has been handled irregularly. This organization lias taken 
upon itself to have apprentices when no one else in the industry 
was allowed apprentices. 

MISS ROHR: We have no apprentices. We hope to have them and 
need them. 

MR. ORE: All we can do is to get the apr>licant's statement as 
to why this should be granted, and the representatives of the Code 
Authority, Industrial and Labor Advisory Board shall make their re- 
commendations as to whether or not it shall be granted. The final 
decision is up to the Division Administrator, but in sending this 
petition to him we will furnish him with the high spots of the record 
of this hearing. If Miss Rohr has anything more to support her claim 
or if there are any other statements, 1 would like to have them. 

MISS SCHITEIDERMAN: I do not see how you can grant a further stay 
without helping the other manufacturers that are in the South and out- 
lying districts. I think this lady has enjoyed an exception no other 
manufacturers have. I think it grossly unfair to the other manufacturers. 

MISS ROHR: While we are making our samples we have had nobody 
but our experts who are well paid so we really have not taken advantage 
until right now. We have quite a number of them back and some of them 
get $12 but most get more. The inefficient have not been called back a s 
yet. 



9811 



-473- 

MR. ORE: That is one reason why we called this hearing. We want 
to settle this case as promptly as possible because Miss Rohr is coming 
into her peak season now. 

MR. MITTE1TTHAL: In view of what Miss Rohr has said, I think it 
most important for her to know just where she stands. 

MISS ROHR: We have absolutely no desire to have any considera- 
tion over above other people. We don't want to "be in a position where 
we can make more money than other people. We want to supply our people 
with work and make a fair profit. Last year in working \mder the code 
we had to "borrow from the "bank. We don't want to make demands on our 
hank. When we were first in business wc made money. We raised our 
people. Then came the lean years and we lost money and the last 2 
or 3 years if it had not been for our slip covers we. would have been 
in the red every single year. I do not consider we offer undesirable 
competition in the handbag industry. The New York stores won't buy 
our bags. We have no market for our pocketbooks in Now 'York because 
we cannot compete with the Hew York firms. Cur people do not work 
efficiently, and we ask just as little as we can ask to make a 
profit. 

MISS SCHNEIDERMAN: When you made the statement "working under 
the code last fall" you meant the President's Reemployment Agreement. 
There vas no code last fall. 

MISS ROHR: Yes. We lost $11,000. 

MISS ORE: You wanted the code to read 30^ instead of "5rf? 

MISS ROHR: That is what we thought it was going to be, and we 
paid that. 

COLOITEL BERRY: How many people are you now paying $12 to? 

MISS ROHR: There are 8 people out of 51 employees getting less 
than $14. 

COLONEL BERRY: There is e question whether this stay should be 
-terminated or whether it should be extended until we can have a hearing 
on a territorial differential. We expect to propose the amendment pro- 
viding for a territorial differential. We can't grant a permanent 
exemption. 

MR. TAYLOR: When does the fall s eason begin? 

MISS ROHR: Right now. 

MISS SCHNEIDERMAN: May I draw your attention to if what Colonel 
Berry says is going to happen — if this industry is going to be brought 
up to a higher minimum of 40^ — even if she gets a territorial differential 
her rate per hour is going to be higher than it is right now. 



9811 



QOLONEL EERRY: Yes, and -for her competitors too. In these oth r 
codes there is a 2;V differential "between male and female < > 

MISS SCHNEIDSRMAlTr I will not stand for a differential for women 
if I have anything to do with this case. 

MR. BASE: In the same payroll there are about 20 out of 51 

getting $18 and over, and some as high as $35 and $40, and one $75 
a week. I think this payroll shows a fine wage scale. This payroll 

does not present a picture in which it can he said the code .minimum works 
a hardship. 

MR. ORE: If this stay is terminated you will, of course, ahide "by 
the code? 

MISS ROHR: We'll have to. 

MR. ORE: It is the duty of the Deputy to take the facts as sub- 
mitted here and then submit them to the Division Administrator with 
his recommendation. You are operating under a stay until the order 
comes deciding' this cose. Tie do not .want to tie up your "business 
until the stay is terminated, and in either case you will have to comply 
with the code. Therefore, it will bo necessary for the Code Authority 
to issue labels to the Virginia Art Studios now. 

MR. BERKOYIITZ: They will heve to sign the compliance form. 

MR. ORE: Issue the labels to Miss Rohr, and it will be the dis- 
cretion of the Division Administrator as to how ho shall act upon the 
stay. I know you will immediately com sly with the code when and if 
the stay is terminated, and I would suggest that yon prepare yourself 
for a raise in wages, and it would be well to figure them in your 
forthcoming merchandise. : 

MR. MITTEdTHAL: Shall I consider that an order from you to issue 
the label. 

MR. ORE: Yes. 

COLONEL 3SRRY: If you can sustain yourself for a territorial 
differential, it will be determined on fact. 

MISS ROHR: We have a man who has had a great deal of eineriencc 
who is at the head of our production. He s-?id he would be glad to make 
a statement in regard to the difficulties. 

MR. ORE: They should be submitted to the Code Authority. Do you 
want a differential for women? 

MISS ROHR: No. Our women get the same as the men because we are 
a women's organization. 



9811 



-480- 

MR. TAYLOR: Under the conditions you outline of an increase in 
wage for the industry, no matter how this turns out Miss- Rohr will have 
to increase the $14 s week workmen, will she not? 

C0L01TEL BERRY: My recommendation' will he that this stay continue 
until the hearing next month when she will have an o;r~>ortunity of pre- 
senting an amendment for territorial differential. If that is thrown 
out she will have to abide by the code ?.s it now stands. 

MR. TAYLOR: She' will nave to increase her wages within a month 

from now anyway. Since it only makes a few weeks difference for only 

8 workmen, can we not terminate the stay now. You will have to increase 
those few yrorlamen anyway. 

MR. MITTEUTKAL: When they reduce their force from 160 to 51 they 
maintain the key people and the irregular workers are not let go. 

KISS ROHR: We never have 160 people in the fall. In the spring 
the work we do is not for the most part skilled work. There is no real 
pockethook work. We fold our cotton foundations on a machine and the 
outside covers are sewed up and the embroidery put on by- hand. It is 
to make that sort of thing that wo employ so many people. 

MR. BARR: hiss Rohr's testimony regarding the nature of her work 
brings her further away from line. She does very little in the fall. 

LiR. MITTEiTTHAL: Miss Rohr when siio says slip covers refers to a 
slip covering a ladies' handba^. 

COLONEL 3ERRY: A suggestion to the Code Authority. Would it help 
you any if we terminated this stay and granted an exemption for 30 days 
until the first of September? 

MR. MITTEHTIIAL: We would have to have a very good reason. 

MR. ORE: So far as bring her in compliance today, that would 
prove to the industry she is under the code. Then if she gives us 
sufficient evidence an exemption should be granted, until en amed— 
ment can be heard in public hearing, I .think that would help your 
situation and be agreeable to the Labor Advisory Board. We will re- 
commend to the Division Administrator this stay be terminated. The 
burden of furnishing evidence which would support an exemption for 
a limited time until you can furnish the Code Authority with material 
for an amendment to the code will be on you. You will be under the 
code until such time as you can procure an exemption order. 

COLONEL BERRY: Would it satisfy the Code Authority people if you 
told them the -stay was automatically by itself being enforced and will 
be terminated on September 1?'' 



9811 



-431- 
MR. i'JTTSHTHAL: What would be the action of the other -iro-oosal? 

COLONEL 3SRRY: If it is granted now, she would have to go under 
the code right away. 

MISS SCffiTEIDSRMAlT: I think I have my point of view maybe entirely 
wrong. This lady has enjoyed a differential which no one else in the 
industry has had. It seems to me this stay ought to he terminated, and 
since it is only a question of 4 weeks and "mow the wage will go up, 
I dont think it would harm the business of the Virginia Art Studios 
group to come under the code and comply until there is a hearing. 

After this statement by Miss Schneiderman, Colonel Berry began a 
discussion about amending the code and substituting a 40^* minimum and 
deleting sections 2 and 6 of Article IV. of the present code. He also 
requested the Code Authority to send in their amendments to the Code 
and Miss Rohr was asked to do the same thing. This discussion was 
quite lengthy. Coming back to the question of an exemption for the 
Virginia Art Studios, Colonel Berry asked: 

COLOITEL BERRY: Would this be satisfactory? Terminate 'this 
stay July 31 and grant you an exemption effective August 1 for the 
month of August pending a. hearing on. a proposed amendment.. 

MR. M1TTMTHAL: That sounds reasonable. 

COLONEL BERRY: I am willing to do that. 

MR. BARR: These stays have to be terminated with or without 
exemption. 

MR. TAYLOR: Does the Code Authority have any amendments to 
propose? 

MR. MITTENTHAL: We shall have if the; accept this wage settle- 
ment and also on other matters — on the cost formula and price groupings. 

MR. ORE: It is going to be absolutely necessary for Miss Rohr to 
furnish all data requested by the Code Authority. 

MISS ROHR: May I have that outline. I sent it to Mr. Glass but 
I will be glad to submit the material. 

MR. ORE: You can deal with the Code Authority on that matter. 

MR. BSRKOVJITZ: Miss Rohr states they have not used any apprentices 
since March 26. 

MISS ROHR: I_did not say that. We have not had any for quite some 
time. We raised them to $12, those we did have. 

MR. BARR: Miss Rohr would not be required to pay any back pay. 



9811 



-432- 



MISS SCHLT2JID3RMA1T: Are we giving this lady an exemption before she 
turns in her statement? 

MR. 0E3: II . 

MISS SCHNSIDjEMAN: I think the Deputy is stating an exemption 
should be granted her. I do not think that is the right way of doing it. 
Also, do I understand that in that exemption we are permitting learners. 

MR. ORE: There are no apprentices. Miss Rokr, will you follow 
the trade practices of the Code? 

MISS ROHR: Absolutely. 

MR. ORE: The hours? 

MISS ROKR: Absolutely. 



» • » * • 



► 



MR. ORE: You have not paid any coTe assessments and you have not 
been paying the wages, nor supplied the statistics; 

MR. TAYLOR: The only exemption Miss Rohr would have would be for 
a few employees at a wage rate below the minimum. 

MISS ROHR: I would like you people to see our wages for the fall. 
If we could have a differential for the fall we would not care about it 
for the spring. . - 

MR. MITTENTHAL: A loss of $11,000 is not much in our industry. 
There is no one in the industry who took those losses who was getting 
an unusually high salary or not justified by their business. When they 
came under the blanket code they did not laiow what the difference was 
going to be in their labor cost. They did not allow enough. They 
continued to sell at the same prices and the differences in their 
payrolls created that loss. The repairs on handbags amounts to 2jo 
of the volume of the sales. 

MISS ROHR: We charge for all our repairs. And we knew it was to 
our interest to go out of business in the fall and manufacture only in 
the spring, but we have gone ahead with patented orders we knew we 
could put out in the spring. We have nothing in the spring because 
after we originate an idea we can go ahead with it. We want to stay 
until 'we can pay back our bank loan so that we will be able to stay 
in business. 

* 

After instructing the Code Authority *to is sue 'labels to the 
Virginia Art Studios, and after again outlining the plan to be followed 
in this case, the hearing was brought to a close by Mr. Ore. 



9811 



EXHIBIT A.l. 
M3MDRAHDUM 

July 30, 1234 

TO: George L. Berry, Division Administrator 

FROM: Harry S. Berry, Deputy Administrator 

SUBJECT: Termination of Stay. 

By reason of the fact that the Virginia Art Studios, Inc., 
Lynchburg, Virginia, protested the terms of the Ladies' Handbag Code 
within ten days after it was approved, this concern was automatically 
granted a stay from its provisions in accordance with the Executive 
Order of July 15, 1933. 

Hearing was held in this office at which time Mamie E. Rohr, 
President and Treasurer, was given the opportunity to present all evi- 
dence to substantiate her claim for further stay from the provisions 
of the Ladies' Handbag Code. At the hearing the Industrial Advisory 
Board was represented by Mr. T. R. Taylor, the L?bor Advisory Board 
by Miss Schneiderman, the Code Directors Mr. Mittenthal and Mr. 
Berkowitz, Assistant Deputy Administrator Leigh E. Ore and David 
Barr, and myself. The relevant facts pertaining to the case are 
attached. 

After carefully reviewing all the facts, I recommend the stay be 
terminated forthwith in order that the Code Authority may advise the 
industry this stay has been acted upon in the regular manner. The 
Code Authority Directors, the Industrial Advisory Board and the Labor 
Advisory Board agree with my decision. 

I am, however, recommending in a separate document that an 
order for exemption be executed in behalf of the Virginia Art Studios 
which will permit this company to pay a minimum as low as $12 per week 
instead of the $14 per week as provided for in the code until such time 
as the code can be re-opened to consider a southern differential, which 
if evidence shows is necessary, will give the Virginia Art Studios the 
relief they seek. 



(signed) Harry S. Berry 
Harry S. Berry 
Deputy Administrator 

At tachment 



9811 



-434- 

MTIOIJAL aaCOySBT ADMINISTRATION 
WASHINGTON, D. C. 



August 10, 1934 



To: Harry S. Berry, Deputy Administrator 

From : Labo r Advi so ry Boa rd 

Subject: Code of Fair Competition for the 
LADIBS' HANDBAG INDUSTRY 



We do not approve of the proposed order granting the Virginia 
Art Studios, Inc., Lynchburg, Virginia, an exemption from the pro- 
visions of Article IV, Section 1, of the Code of Fair Competition 
for the LADIES' HANDBAG INDUSTRY. The minimum rate in the code is 
o5<p per hour, or $14.00 per week. The proposed order would permit 
30^, or a $3.00 per week, differential. This is out of line with 
the differential permitted in industries which employ similar type 
of labor, practically all of which include a $1.00 differential. 



LABOR ADVISORY BOARD 
(s) B y . A. H. Myers 



AHM/mc 



9811 



-435- 



Col. Harry S. Berry, 

Administrator of Division 3,' 

National Recovery Administration. 

Your Petitioner, the Virginia Art Goods Studios, Incorporated, a 
Corporation organized under the laws of the State of Virginia, engaged 
in the business of manufacturing and selling Ladies' Handbags, respect- 
fully represents: 

1. " That it is operating under the Code of Fair Competition 

for the Ladies' Handbag Industry, as approved on March 14, 
1934, except as to the labor provisions thereof relating 
to the minimum wage scale, as to which it is operating under 
an exemption order expiring Sept. 1, 1934. 

2. That the date for the expiration of said exemption order, 
as petitioner is advised, was fixed in anticipation of a 
hearing before that date upon pixnosed amendments to this 
Code relating to labor and wage scales. 

3. That it is now apparent that such hearing will not be held 
prior to September 1, 1934, and in order to -oroserve the 
petitioner's status under its protest duly filed in 
accordance with Executive Order #2, of July 15, 1933, the 
exemption period should be extended to such date as the 
anticipated hearing shall have been held and the proposed 
amendments disposed of. 

4. That there are attached hereto to be read as evidence in 
further support of its right to such extension herein 
prayed for, the following documents; 

(a) Copy of letter, dated Larch 30, 1934, from 
Robert D. Ramsey, Business Manager of the 
Chamber of Commerce of Lynchburg, to 
James C. Worthy, Assistant Deputy Adminis- 
trator, National R3Covery Admini strati on. 

(b) Affidavit of Mamie R. Rohr, President of 
Virginia Art Goods Studios, Incorporated. 

(c) Affidavit of Sdnrand Waltuck. 

(d) Affidavit of 0. H. Tufts. 

5. That a copy of this petition has been forwarded with copies 

of the attached documents to the Code Authority, Ladies' Handbag 
Industry, 347 Fifth Ave., Hew York. 



9811 



Wherefore your Petitioner respectfully prays tliat a prober order 
be issued extending the period of its exemption from Code provisions 
relating to labor, to such date as proposed amendments to said Code 
providing for wage differential for the sourthern territory .shall 
have been given a hearing. 



VIRGIHIA ART. GOODS STUDIOS, IHC . 

By /s/ Mamie E. Rohr 

Pres. 



Attest: 

/s/ Bertie R. Thornhill 
Secretary. 



9811 



-437- 

August 31, 1934. 

Mr. Leigh N. Ore 

Assistant Deputy Administrator 

Commerce Buildirff; 

*— Sir- r 

Washington, B.C. 

Dear Mr. Ore: 

The Virginia Art Goods Studios, Inc. presented a petition for an 
amendment to the Code of Fair Competition for the Ladies 1 Handbag 
Industry by adding to Article IV of the Code, the following section: 

(a) In the States of Virginia, North Carolina, South 

Carolina, Georgia, Florida, Mississippi, Louisiana^ 
Alabama, Eenness^ aA r Tex^is, the minimum wage for 
•unskilled enmloyees shall oe ZQd ">er hour: 



(b) The minimum wage for semi-skilled employees shall be 
37g$ per hour. 

(c) Learners may be employed for a period of not exceeding 

ten weeks at a minimum wage of 24,i per hour, provided 
that the number of such learners shall not at any time 
exceed 15 per cent of the entire number of employees. 

The petition was supported ''c:/ the follov:ing documents: 

(a) Copy of letter, dated March 30, 1934, from Robert D. 
Ramsey, Business Manager of the Chamber of Commerce of 
Lynchburg, to James C. Worthy, Assistant Deputy Adminis- 
trator, national Recovery Administration. 

(b) Affidavit of Mamie 3. Rohr, President of Virginia Art 
Goods Studios, Inc. 

(c) Affidavit of Edmund Waltuck. 

(d) Affidavit of 0. H. Tufts. 

The Virginia Art Goods Studios, Inc. states that a copy of its peti- 
tion was also sent to Col. H. S. Berry, Deputy Administrator. 

After careful consideration oef the statements made and the evidence 
presented in these documents, <he Code Atrtnority, at a meeting' held August 
30, 1954 at the Hotel McAlpin, voted' to deny the petition of the Virginia 
"TKfTTJ&TJtts Studios,- for an amendment to- the C ode-ja-jabijib they request; 



9811 



-488- 

(a) to be granted a differential in wage rates in favor 
of the southern territories. 

(b) to fix a minimum wage for semi-sl-:illed workers at 
Z1A per hour. 

(c) to "oermit learners for a period of ten weeks at a 
minimum wage of 24^ per hour, not to exceed 15 per 
cent of the entire number of employees. 

The Virginia A r t Goods Studios, Inc. in support of their petition 
claim that the manufacturers of Ladies' handbags in the northern states 
have' skilled labor who work with a "s^eed which can be equalled only by 
equally skilled experienced labor." 

Fifty percent of the handbag industry is located outside the metro- 
politan area of New York in which no experienced help is available, and 
the manufacturers obtain their workers in tlie same manner as does the 
Virginia Art Goods Studios, Inc. In the metropolitan area of Hew York, 
in which experienced help is available, the wages paid such help is from 
two to three times more than paid the inexperienced help. 

The Virginia A r t Goods Stxvion, Inc. claim that they a re pioneers 
in their locality. 

The records show this firm has been established over eight years, 
and that during the past five years, they have enjoyed a large vokurae 
of business in the industi^-, employing at times as many as 168 workers. 
These workers have all had some training by this time, and are •'-•vail- 
able mostly at the minimum wage rate. The question whether the labor 
in Lynchburg, Virginia can compare with northern workers in volume in 
speed of productic. is not determinable, since the kind and quality of 
work varies m each factory, and lack of production frequently the re- 
sult of inefficiency in factory managements as has been disclosed 
through investigation made in other industries in which similar claims 
have boon made. 

The statement of the Virginia Art Goods Studios, Inc. that "the 
practical and inevitable resxilt is that the Virginia Art Goods Stuchios, 
Inc. cannot successfully compete with other manufacturers whose outout 
per capita of employees is so much greater" — this merely expresses their 
opinion. 

The loss sustained by the Virginia Art Goods Studios, Inc. during 
the year 1933 may have been due to a dozen or more causes, and to have 
this Company claim that such losses rjsulted from increased labor costs, 
is merely expressing a convenient conclusion. Any increase in labor costs 
might have been included in the cost . of their nroduct, or they have offset 
this increase by taking the difference out of the value of materials,^ 
if they fail to do so, they cannot justly attribute it to increased labor 
costs. 



9811 



-489- 

From the figures furnished by the Company of their sales and sales 
costs, it world appear that they are pricing their goods without ? safe 
and adequate profit. 

The test of efficiency in workers made by their production manager, 

is not based on fact, it is merely expressing his individual opinion. 

The statement that the products of the Company are sold at a higher 
Trice than the products of northern factories is not sustained, particul- 
arly since this Company manufactures a unique line of handbags, diff- 
erent from the bags manufactured by other firms in the industry, and 
further they are protected by patents which they have attested to. 

The Virginia Art Goods Studios, Inc. do a good volume of business 
and they are rated financially as one of the outstanding firms in the 
indus t ry . 

It is not necessary for the Virginia Art Goods Studios, Inc. to 
obtain lower wage rates in order to compete with factories in the 
northern territory, and the fact that they have suffered a small loss 
during the year 1933 is due to the sane reasons that caused other 
factories in the industry to suffer larger losses, all due to the fact 
that they are trying to give too great varues at the prices. 

The request to amend the Code to allow a wage rate of 37^ for 
semi-skilled workers cannot be coiiLidered since there is no defini- 
tion of a semi-skilled worker in the Code. 

The request to amend the Code to nermit learners is denied by the 
Code Authority at the present time, and until the Code shall be amended 
by agreement vith the Administrator to provide learners for the entire 
industry. 

The Virginia Art Goods Studios, Inc. has been operating under a 
stay since the effective date of the Code, March 26, 1934. This stay 
expires Scptombei 1, 1934. The Code Autnority protests against the 
continuance of their stay beyoyond September 1, 1934, since the 
Virginia Art Goods Studios, Inc. had the entire month of August during 
which they might have siibmitted their petition. However, they failed 
to do so until August 27, 1934 and they are now requesting that the 
exemption period should bo extended to such date as the anticipated 
hearing shall have been held, and the proposed amendments disposed of. 

Very traly yours, 

CODE AUTHORITY 
LADIES' HA1TD3AG INDUSTRY 



iiittenthal 

Code Director 



AM: AS 



3811 



-490- 

C TH3 VIB&II7IA ART GOODS STUDIOS, IilC. 

o 

p lynchburg, Virginia 

y 



March 8, 1935 



Colonel Robert Lea 

Denuty Administrator for Industry 

Washington, D. C. 

Dear Colonel Lea: 

I am not sure that you are the -oerson I should ha Writing to, hut 
since you are the one whom I saw when I came to Washington Inst summer, 
and the one who arranged the conference with Col. Ore and sevarrl others, 
I am writing this to you, and ask if some one else is the "irower one 
for me to com unicate with that you pass this letter on to him. 

You will remember that at the time I came to Washington we were 
asking for a minimum wage of $12.00, with an apprentice period of three 
months during whicn time we should be allowed to pay COp of the minimum. 
We had been laying on this basis in accordance with the President's agree- 
ment that we should be permitted to depart from Code requirements if we 
protested against any of these requirements before a certain date (which 
we did) until such time as a meeting should be held to determine the 
justice of our report. At the meeting you arranged in Washington it was 
tentatively agreed that we be allowed a minimum wage of $12.00, with no 
apprentice period, with the understanding that by September there should 
be a final decision in regard to a differential and an apprentice 
"~eriod for Southern industries. 

As far as we I:now there has been no decision made on those joints, 
yet we have continued all these months to live up to this tentative 
agreement. During the fall period we lost $18,000.00, which you can 
well understand is not ,._;ood for an industry. We have no\7 entered 
uoon a spring season during which period it is absolutely essential 
that we make a profit if we ex:ect to continue in business. During 
the fall we did not need to employ untrained "oeo ile as our re ular 
corps of workers could take care of our business. We are now, however, 
in need of employing a number of new untrained people, and it is 
absoln.tely essential that we be allowed to pay them less than the 
minimum wage until they ? re broken in to the work. As you know 
there are no trained people in this section except the ones we have 
trained. We feel that under the President's agreement we have a right 
to an apprentice ^eriod until some definite decision is reached in regard 
to this matter. We are, therefore, this time employing the extra people 



9811 



-491- 



we need at 80,3 of $1.3.00, until such time as they are able to do the 
v/ork efficiently. 

We have tried to live tip to what we agreed to do, and we feel 
that we want to make our position in this matter clear. 



Very truly yours, 

Mamie E. Rohr, President 
:HS VIRGINIA ART GOODS STUDIOS, ISO, 



M3R/A 



9R11 



-492- 



Liarch 11, 1955 



Mrs. Mamie S. Eohr, 

President 

The Virginia Art Goods Studio, Inc. 

Lynchburg, Virginia.. 



Dear Mrs. Rohr: 



Your letter of March 8th, addressed to Col. Robert Lea, 
has been referred to me as the Ladies' Handbag Code is at 
present under my direction. 

This code provides for a minimum wage of $14.00 per 
week, and there is no provision for learners or apprentices. 
Any agreement to the contrary would not be valid. Ho one with- 
out first obtaining an exemption has a right to work any employee 
other than in accordance with the provisions of the Code. 

If you feel that the code provisions are working a hardship 
in your instance, will you kindly write asking that you be granted 
an exemption. You should state the number of persons whom you 
intend working as apprentices, and for what period of time - also 
the amount that you intend paying them during the apprentice 
period. Please state the total number of yotir emoloyees, and 
any other facts which you think are -^retinent toward giving force 
to your contentions. 

Your application for exemption will be "out through the 
regular channels, and you may rest assured it will be given every 
consideration. 

Very truly yours, 



Walter Mangum 
Deputy Administrator 
Textile Division 



R-21373 



9811 



-493- 



TH3 VIRGINIA ART GOODS STUDIOS, IK), 
1306-1310 Church Street 
LYNCHBURG, VIRGINIA 



March 12, 1935. 

Mr. Walter Mangum 

Deputy Administrator 

Textile Division 

National Recovery Administration 

Washington, D. C. 

Dear Mr. Mangum: 

W e are just in receipt of your letter of March 11th in answer 
to ours of March 8th addressed to Col. Robert Lea. 

First, in regard to the second paragraph of your letter, we 
are well aware of what the Code "provides". These provisions 
were made without our sanction as we have in innumerable letters 
to Washington set forth. 

In the very beginning the President announced that if the 
provisions "of the Code worked a hardship, a firm had a right to 
a stay provided said firm entered a protest before a certain date, 
said stay to be effective until such time as a meeting should be 
held and action taken in regard to the points against which pro- 
test was entered. 

It seems quite surprising to us that before answering our 
letter you had not looked up the correspondence we have had with 
ERA in regard to this matter. You state in the third paragraph of 
your letter that if we feel the Code provisions are working a hardship 
that we should write asking to be granted an exemption. It would cer- 
tainly seem that something of all the agitation 3f this question would 
have come to your ears. As we wrote in our letter of March 8th, ac- 
tion was to have been taken on our case by the first of September, but 
no action was ever taken that we know of. We wrote elaborate explana- 
tions, giving in detail our grievances, and stating why it was abso- 
lutely necessary if we are to stay in business that we be allowed at 
most a $12.00 minimum wage and an apprentice period of 80,j of this 
amount. Perhaps it would be well for you to look in the files and 
learn what the situation is. 

We wish to say once more that we consider we are still allowed 
the stay which the President -agreed we might have, since no action 
has been taken on our protest. We are, therefore, paying a limited 
number of beginners unfamiliar with the handbag industry $9.60 a 
week while they are training. 

As soon as our application for an exemption, filed . last August, 
is put through "regular channels" and a decision is made, we shall be 
glad to have a report on it. 

Very truly yours, 
THE VIRGINIA ART GOODS STUDIOS, INC. 
ins/ A Per (signed) MAMI3 3. R0HR, 
9811 Pres. 



-494- 

March 18, 1935 

Mrs. Mamie E. Rohr 

The Virginia Art Goods Studios, Inc. 

Lynchburg, Virginia 

Dear Mrs. Rohr: 

Your letter of March 12th lias been received. 

You are quite right in stating that the stay which was granted 
is still in effect. 

The Code Authority recently informed me that they are making 
an application for a termination of the stay. They feel that it 
is unfair to other members of the industry, and are asking us to 
take quick action. You, of course, are very familiar with all 
the facts of the case so I will not again go into them. They have 
a right to ask that the matter be brought up for hearing, and I 
would like to know if you are agreeable to having an informal one 
rather than going to the expense of having a formal Public Hearing. 
If this meets with your approval, I can then set a date which will 
be mutually agreeable, as I understand their formal request will 
probably arrive here tomorrow. 

For yc :.v information, I have only recently t?ken over this 
section and, therefore, have no knov/lcdge of the matters which 
happened last year, and unfortunately, the days are not long 
enough for mc to read through the files as quickly as I would like. 

Very truly yours, 



Walter Mangum 
Deputy Administrator 
Textile Division 



9811 



-495- 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Fifth Avenue 
KM YORK 

Col. Walter Mangum 
Deputy Administrator 
Commerce Bldg. , 
Washington, D. C. 

Dear Col. Mangum: 

The Code Authority -.at a meeting held on March 7, 1935 passed the 
following resolution: 

RESOLVED, that the Code Directors be and are hereby 
cirected to request the Administration to terminate 
the exception to the minimum wage rate granted to the 
Virginia Art Goods Studios, of Lynchburg, Virginia on 
August 1, 1934. 

Since this exception was granted to the Virginia Art Goods Studios, 
the Code Authority has requested a number of times to have it termina- 
ted. The Code Authority lias been greatly embarrassed by having the 
Virginia Art Goods Studios and the Pat Bag, Inc., of Richmond, Va. 
the only members of the industry granted an exception to the code 
wages, since 'numerous requests from other members of the industry for 
the same exception to the code have been refused in every case. 

Other members of the industry when found violating the wage 
provision of the code, have attempted to justify their right to do 
so by referring to the exception granted the Virginia Art Goods 
Studios. The continuation of this stay is regarded by the remain- 
der of the industry as being discriminatory. 

The Code Authority herewith requests that this inequality in 
the industry shall be terminated at once by the Administrator, and 
that if necessary, a hearing be held immediately for that purpose. 

The Code Authority also asks that the exception granted to the 
Pat Bag, Inc. shall also be terminated, and that if found necessary, 
they should be included in a hearing that may be called for this 
purpose. 

Very truly yoiirs, 

CODE AUTHORITY 
LADIES' HAHDBAG- I1TDUSTRY 
(s) A. MITTKTTHAL 
CODE DIRECTOR 



9811 



-496- 



March 25, 1935 



Mr. A. Mittenthal, Code Director 

Code Authority, Ladies' Handbag Industry 

347 Fifth Avenue 

Hew York, 1!. Y. 

Dear Mr. Mitten thai: 

I have your letter of March 19th with 
reference to the Stay under- which the Virginia 
Art Goods Studios are operating. Under date of 
March 18th I wrote Mrs. Rohr as per attached copy. 
I have had no reply yet but trust one will be 
forthcoming within the next day or two. 

You may rest assured that it is my de- 
sire to clear up this situation as soon as it is 
phy ically possible to do so. 

Very truly yours, 



Walter Mangum 

Deputy Administrator 

Textile Division 



DEH: sk 

Enc. (l) 

Copy of letter 



9811 



-497- 



CODE AUTHORITY 

LADIES' HANDBAG- INDUSTRY 

347 Fifth Ave. 

NEW YORK 



March 27, 1935 



Col. Walter Mangum 
Deputy Administrator 
Commerce Building, 
Washington, D. C. 

Dear Col. Mangum: 

I am in receipt of your letter of March 25 in reference to 
the matter of the Virginia Art G-oods^ Studios. 

I certainly appreciate your efforts to hring this matter 
to a satisfactory solution. Any conference or hearing that 
you may call for this purpose, I shall "be glad to attend. 

Very truly yours, 

(signed) A. MITTENTHAL 
A. Mittenthal 
Code Director 
Ladies' HandDag Industry 



AM:AS 



9811 



493- 



THE VIRGINIA ART GOODS STUDIOS, INC, 
1506-10 Church Street 
LYNCHBURG, VIRGINIA 



Apr. 20, 1935 

Col. Walter Mangum 

Deputy Administrator 

Textile Division 

National Recovery Administration 

Washington, D.C. 

Dear Col. Mangum: 

Recently we wrote to the Code Authority for our Industry in 
New York telling him of the difficulties we have been having in 
trying to operate with a profit and to turn out the necessary 
amount of goods in tne time required. In response to this appeal, 
Mr. Max Berkowitz made a trip down to Lynchburg to see us, and made 
a very careful study of our problems in the limited time he could be 
with us. 

We want to say that we found Mr. Borkowitz most cooperative, 
and very ranch interested in our situation. He realized that wo 
were in a very serious situation and made suggestions which wo 
felt were very corstruc r:\ r e, and which we should like very much 
to try to carry out. Wo believe as he does that if wc could follow 
his suggestions we would be able to put our business on a paying 
basis, and not find it necessary to ask tne Code for exemptions 
from the regular requirements. We want very much te do this, and we 
want to be in a position to pay our employees, who are very loyal 
and cooperative, just as much as possible. 

If Mr. Borkowitz were in a position to stay with us for several 
days wc believe he would be of inestimable value in helping us solve 
our problems. Do you think he could be spared to us for a while? 
We realize that this is asking quite a rood deal — that he is a very 
busy man and that in his ocsition he has a great many things to look 
after — but if he could be lent to us for a short while maybe our 
industry would cease to be a problem. If it would be possible for you 
to send him to us we would like to have him come as quickly as he 
conveniently can. Kindly let us hear from you. 

Sincerely yours, 

(signed) MAMIE E. ROHR, Pros. 

TIE VIRGINIA ART GOODS STUDIOS, INC. 



MER/a 



9811 



Colonel Walter Mangum 
Deputy Administrator ^ 
Commerce Building 
Washington, D. C. 



Dear Colonel; 



-499- 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 
347 Fifth Avenue 
NEW YORK 

April 23, 1935 



o <f 



Re:. Virginia, Art Goods Studios, Inc, 
1306-1310 Church Street 
Lyn chburg , V i rg i n i a 



I have made a careful investigation of the conditions in the 
factory .of the above firm and have found that they have been work- 
ing overtime from April first on, averaging from 2~k to 24 hours 
per person. I have made arrangements -with them to pay time and 
a half for this overtime work which they have agreed to do. A 



list of the workers 'and the amounts wi' 
the next few days. 



11 be in our office within 



Miss.. Rohr, president of this firm, stated to me that she had 
received an exemption from you for apprentices. We fail to find 
in our files any correspondence, ~W copies of srrme-, with reference 
to this statement. 

The attached report gives the number of workers who were em- 
ployed below the Code minimum from December 19, 1934 to date. 

We will appreciate it if you will send us copies of any 
correspendence that you may have had with this firm in order that 
we may straighten these matters out. From what Miss Rohr has 
promised the writer, she v/ill come definitely under all the pro- 
visions of our Code. 

? « a o *• o * 
Very truly yours, 

CODE AUTHORITY 
IADIES 1 HANDBAG INDUSTRY 



Max Berkowitz 
Code Director 



3ncl — List showing overtime and 
payroll violation 



9811 



"W 



-500- 



Special Investi^ati 



on 



The investigation discloses the fact that this firm has two factories — 
one an annex which employs about 20 workers. 

Workers were employed at rates below the minimum wage as follows: 



uate : 


No. 


enro. 


.oyed at 




30 $ 


"oer 


hour 


12-19-34 




39 




12-25-34 




43 




1- 9-35 




39 




1-23-35 




42 




2-: 6-35 




56 




2-20-35 




61 




3- 6-35 




55 




4- 3-35 




60 




4-17-35 




61 




Annex: 4-17 


6 





Nn. employed at 
35^ per hour , 



Ho . Home— 

workers __ 

4 

12 

14 
9 
25 : 31 

8 
2 6 32| 

Overtime — 4-1-35 from 2i hours to 24 hours per person 



Total No., of. 
Smployees 

93 



110 
120 
128 
183 

18 



4-3-35 Overtime was registered on individual cards. No 
entry was made in the book. The overtime amounted to 
about $300 straight time. 



Max 3erkowitz 



mb s 



9811 



-501- 



April 24, 1935 



Mr. Max Berkowitz 

Code Director,- Code .Authority 

Ladies 1 Handbag Industry 

347 Fifth Avenue 

New York, II. Y. 

Dear Mr. .Berkowitz: 

I am attaching hereto copy of letter just received from 
Mrs. Hohr and m; : reply; I know you -will do everything you 
can to comply with the request in the final paragraph of 
her lettsr. I appreciate also that you are not twins and 
can only do a certain amount of the good work which you are 
doing. 

Very truly yours, 



Owen A. Locke 
Assistant Deputy Administrator 
Textile Division 



DEH:sk 

aic. (2) 

Conies of" Letters 



-502- 



April 24, 1935 



Mrs. Mamie Si Hohr, resident, 
The Virginia Art Goods Studios, 
1306-1310 Church Street 
Lynchburg, Virginia 



Inc. 



Dear Mrs. Hohr: 

He have your letter of April 30th, and are very pleased 
to note that the recent trip made to your plant by Mr. Berko- 
witz was of such great benefit. 

You, as a handbag manufacturer, are most fortunate in 
having such men as Mr. Kerkowitz and Mr. Mittenthal directing 
the Code of your industry. 

While it is not for us to dictate, but is purely up to 
the discretion of the Code Authority, I am today writing Mr. 
Berkowitz urging nim to comply with your request outlined in 
the last paragraph of your letter. I know that he will be glad 
to do so if it is at all possible. 

Very truly yours 



Owen A. Locke 
Assistant Deputy Administrator 
Textile Division 
DEH:sk 



9811 



-503- 



EXHIBIT B -1 



Tr^de Practice Complaints Committee 



> 



9811 



-504- 
EXHIBIT B-l 



COLE AUTHORITY 

LADIES' HANDBAG INDUSTRY 

303 FIFTH AVENUE 

HEW YORK 



April 11, 1934 



Dr. E.-rl Dern Howard 
D eput y Admi ni s t r at o r 
Department of Commerce Bid/;,-. 
Washington, D. C. 

Dear Sir: 

We herewith present r. resolution passed "by the Code 
Authority fit n. meeting held at the Hotel HcAlpin, 
April 11, 1934, requesting authority to handle F~ir 
Trr.de Practice complaints in the first instpnce. 

We are requesting that this he granted so as to 
permit the Code Authority to expedite the handling 
of these complaints involving fair trade practice 

violations under the Code for the industry. 

Very truly yours, 

CODE AUTHORITY 
LADIES' HANDBAG INDUSTRY 

AM: AS /s/ A. LilTTElJTHAL 

A. Liittenth-1 

Code Director 



9G11 



-505- 

CODE AUTHORITY 
LADIES' HAITDBAG IETDUSTHY 
303 FIFTH AVEHUE 
HS17 YORK 



April 11, 1934 



Dr. Srrl Le-n Howard 
Deputy Administrator 
Department of Comae re e 31 dj. 
Washington, D. C. 

De.T Sir: 

At r meeting of the Code Authority for the Ladies' 
Hr.ndb: .g Industry held nt the Hotel McAlpin on 
April 11, 1S34, the following resolution w.s passed: 

"Be it resolved that the Code Authority rsk 
the NptionrJ. Recovery Administration for 
authority to handle the Fair Tratfe Practice 
complaints in the first instance. " 

Very trr.ly you.rs, 

CODE .AUTHORITY 
•LADIES' HAUDSAG INDUSTRY 

ALilA /s/ A. LITTEETHAL 

A. LittenthrQ. 

Coc.e Director 



I hereby certify that the rbove resolution was 
Cull made, seconded -nd passed by the Code Autho- 
rity of the Ladies' Hrndbag Industry. 



/s/ Irviiy: Schoenliolz 



Secretary 

Code Authority Ladies' Hrndbrv 

Industry 



:sn 



-506- 

WASRT'GTON EC 
NBA ROOM 4039 LEO/sh 

SEPT". MBER 27 1924 

A MITTEITTEAL COLE DIRECTOR 
LADIES' IIALTBBAG CODE AUTHORITY 
347 FIFTH AVLIRJE 
HEW YORK CITY 

YOUR TRADE PRACTICE COMPLAINTS COMi.il TTiTB WAS APPROVED TODAY 



LEIGH E ORE 

ASSISTANT DEPUTY ADMIET STRATOR 



TRADE PRACTICE COMPLAINTS COMMITTEE 
OE&AITIZATION MEETING 
HOTEL LIcALPIII, OCTOBER 9, 1934: 



Present: Committee Members - liessrs. Win. C. Rath, Hy Eurstein, Lawrence 
iioss Administration Member - 0. V7. Pearson 
Code Directors - A. Mittenthal, Max Berkowitz 
Executive Secretrry - M, S. Mosesson 



Mr. Mittenthal opener, the meeting ?nd outlined the purpose pnd the work 
of the Committee. 

Administration Member, Mr. 0.- W. Pearson, explained the duties, of the 
members of the Committee, nnd the necessity of keeping correct find 
careful records of all cases brought before the committee for action. 

Code Director,- Max Berkowitz, gave a brief outline of some of the 
difficulties connected with the enforcement of the Irbor provisions 
of the Code as well an the trrde practice provisions. 

Executive Secretary, M. S. Losesson, stated thrt the most important 
work of the committee would be to use moral suasion in such c.-ses that 
the Execv.tive Committee of the Code Authority were not -ble to adjust 
themselves, and it was not the intention of the Directors to burden 
this committee with the multiplicity of small cpses, but to use the 
Committee as a sort of Supreme Court when all other methods fail for 
their purpose. 

There was considerable discussion and questions by the members of the 
Committee. 



9811 



-507- 
Upon motion, meeting rdjournecl p.t 9:00 P. Mi 



R e s p ec 1 f ul 1 y submi 1 1 e d , 



/"/ Li. S. Moses son 

Executive Secretary 



TLXTILL DIVISIOH 
OFFICE OF GOBI: ASrilSTAITT 



Sept. 27, 1934 



To: Assist' nt De >vty Ore 



Administrative Order ITo. 532-17 pert-drd/., - to 
Approval of Pirn ■ nd Officially Authorizing Committee 
to I-Imdle Trrde Practice Complaints idr the Lfdies Hrnd 
Ba :j industry was si ;aec Sept. 27, 1334. This memoran- 
dum constitutes your official notification. 



N. T. Bartlett, 
Code Assist; nt, 
Textile division. 



/s/ G.R.D. 



9811 



- • • -503- 

COMPLIANCE AMII17I STRATI ON 

for the 
CODE 0? FAIR COMPETITION 

for the 
LADIES' HANDBAG IlEUSTRY 

AETICLE I: OEG.TIZATICE 0? TRADE IRACTRE COUPLAIETS COililTTEE 
Section I: Eatio n-1 Irnxe Practice Complaints Committee 

a) The Code Authority shr.ll organize r Rational Trade 
Prrctice Complaints Committee. Said Committee shall be appointed by 
the Code Authority of the L-c.ies 1 Handbag Industry. Said Committee 
shrll appoint an -^equate office and field staff for the effective 
performance of its duties, under the Code. Said Committee shp.il also 
appoint r. le,.~l adviser and Executive Secretary, VTho may devote 

part of his tine to Code Authority duties, other than those of the 
Committee. The Coiimittee shrll be so constituted ,-s to represent in- 
sofar as ractic-'Ole, the different ;roups >and i'literests of the In- 
dustry. It shall e small enough to function elRectively, rnd its 
members shp.il be free to give necessary time to the work of the 
Committee. The Committee shrll make full use of nil available r.nd 
suitpble facilities of national, regional rnd loci association in the 
Industry. An Administration Member of the Code Authority shrll be a 
member of this Coiinittee. He shrll have no vote, but shrll have, r. 
veto, subject to review by the National Industrial Recovery Borrd. No 
party interested in r c-se shr.ll sit on this Committee. The remaining 
members of the Committee shrll elect an adequate number of temporary 
members to make up p quorum. 

b) The National Trade Prrctice Complaints Committee shrll 
elect a Chairman from its ovm membership rnd shrll fix the time of 
regular anc speci"! meetings, and the manner in which such meetings 
"hall be called f:u. conducted. The Executive Secretary of the 
Committee shall* make r report at -11 meetings thereof, of the cases 
hrndlec". by the staff in the interval between meetings, together 
with a strtenent indicating the disposition of r-11 enses closed. 

Section 3: IVnctior.s of National Trade Practice Complaints Committee 

a) The National Trade Prrctice Complaints Committee, 
through divisional and sub- divisional committees, shall have juris- 
diction over all complaints alleging violation of all provisions of 
the Code, except Articles III, IV, and V of the Code, which refer 
respectively" to: 

1. hours of labor 

2. minimum wn ;es 

3. labor provisions 



J811 



-509- 

provided that a complaint by n competitor alleging that an employer 
is violating a. labor provision of the Code, may be h/nr'led by the 
L--bor Complaints Committee, if sue! has teen organized. 

b) She Corimittee in the conduct of its work may: 

1. Prooose to the appropriate agencies, modifier tions and 
of amendments to the Code, which will facilitrte compliance activities; 

2. Lirlce recommendations to the appropriate agencies for 
exemptions and exceptions; 

3. Hake such explanations rnd expositions of provisions of 
the Code as may be required by the c.^ses before them for disposal or 
where such explanations rnd expositions r re pertinent to their work. 

c) The Committ.ee shall hr-ve. tfc-.e responsibility and duty of 
instruction rnd education of persons subject to their jus ri die tions, 
rs to their rights rnd obligations under- the code; the investigation 
and adjustment of complaints of non-compliance in the first instance; 
and the rendition -of the reports to the Appropriate agency in cases 
where, it has been impossible to secure compliance. 

d) The Committee may establish divisional and sub- divisional 
Trade Practice Complaints Committees for Specified territories and 
purposes. -.. 

e) The Coi.imittee shall issue instructions and regulations, 

clearly defining its rules to the divisional rnd sub- divisional 
committees, rnd is empowered to require reports, so that it may be 
fully advisee of the progress of trade compliance work under the 
Code of lair Competition for the Louies' Handbag Industry. 

f) The Committee shall have full charge under the Code 
Authority of trade compliance activities, and shall directly super- 
cise and control rll Divisional and Sab-divisional Trade Practice 

Complaints Committees established hereunder. 

g) Any intere; ted party to a complaint shall not be permitted 
to serve as a member of the Committee hearing such complaint. 

Section 5: Divisional rnd Sub-Divisional Trade Practice Coimlaints 
Committees 

a) In the organization of such c'ivisional and sub-divisionrl 
committees, every effort shall be made to secure representation 
insofar as is practicable, of the different groups and interests in 
the Industry, rnd representation of the public interest in a manner 
similar to that achieved through appointment of °n administration 
member to the Code Authority itself. 

b) Divisional rnd sub-divisional Trade Practice Complaints 
Committees shall elect a Chairman from their own membership, and 
subject to the approval of the Nation* 1 Trade Practice Complaints 

9311 



-510- 

Comnittee, shall ado-it rules of procedure and by-laws. Said by-laws 
and rules shall provide for periodic meetings of the Committees at a 
place conveniently located, so as to give persons having "business with 
such committees, reasonable opportunity for hearing, The Executive 
Secretary of such committees shall report at all meetings thereof a sum- 
mary of the cases handled by the staff in intervals between meetings, 
together with a statement indicating the disposition of cases which have 
been closed. 

c) Divisional and Sub-Divisional Trade Fractice Complaints Com- 
mittees shall submit to the National Trade Practice Complaints Commit- 
tee weekly reports of all cases, and the disposition thereof, arising 
before the divisional and sub-divisional Trade Practice Complaints 
Committees. 

Section 4: Func tjLp.i s^ of_ Divisional .and Sub-Divisional Trade 
Practice C omp lai; its Commit te es 

a) All Divisional and Sub-Divisional Trade Practice Complaints 
Committees hereunder organized snail have jurisdiction over all com- 
plaints alleging violation of all provisions of the Code, subject to 
the approval of the Fational Trade Practice Complaints Committee, ex- 
cept Articles III, IV, and V of the Code, which refer respectively to: 

1. hours of labor 

2. minimum wages 

3. labor provisions 

provided that a complaint by a competitor alleging that an employer 
is violating a labor -->rovision of the Code, may be handled by the La- 
bor Complaints Committee if such has bee'?, organized. 

b) In the conduct of their work, such divisional and sub-divi- 
sional Trade Practice Complaints Committees may: 

1. Propose to the appropriate agencies, modifications of and 
amendments to the Code, which will facilitate compliance activities; 

2. Hake recommendations to the appropriate agencies for exceptions 
and exemptions; 

3. Make such explanations and expositions of provisions of the 
Code as may be required by the cases before them for disposal or where 
such explanations and expositions are pertinent to their work. He- 
quests for interpretations shall be referred to USA. 

c) Divisional and Sub-Divisional Trade Practice Complaints 
Committees shall have the responsibility and duty of instruction 
and education of persons subject to their jurisdiction, as to their 
rights and obligations under the Code; the investigation and adjust- 
ment of complaints of non-compliance in the first instance and the 
rendition of reports to the appropriate agency in cases where it has 
been impossible to secure compliance. 



-511- 
AETICLL II: PPOCLDUPd) I IT TIL. d AhDLIdO OF COLiPLAI" 7 TS 
Section 1: IIFIIITIO.' OF COMPLIAITCE 

Compliance as usee: herein incluo.es:- 

a) The ins tract ion and education of persons suoject to the 
Code concerning their responsibilities thereunder so as to anticipate 
and avoid complaints of non-compliance; 

b) The adjustment of complaints of non-compliance "by education, 
findings of fact, and pressure of opinion within the industry; 

• c) The adjustment of complaints by conciliation, mediation 
and arbitration; 

d) She rendition of reports to enforoement agencies of the 
government in cases where all other means have failed. 

Section 2: ILTIlITIOh QV TdADh PRACTICE COLiPIAirTS 

-3y trade practice complaints for ur oses of these regulations 
shall be understood complaints which allege violations of provisions 

of the Code, other than Articles III, IV rnd V which Articles refer 
to (l) hours of Jj abor, and (,;) Minimum Wages, rnd (3) Labor Provisions, 
provided that a complaint by a competitor pile ;ing that 'rn employer 
is viol- tin, a 1-abor provision of the Code may be handled a" a trade 
practice complaint. 

Section S: jTCPJi OF COiPV AIITTS 

Complaints of Code Violation must be filed in ^writing, preferably 
on the standard form approved by the Code Authority, copies of which may 
be obtained from any agency of the Coue Authority. Anonymous complaints 
will be acted upon only in the discretion of the Complaint Committee 
receivin. ; such complaint. 

Complaints rm all matters pertaining thereto shajl be treated 
strictly confidential by the Committees to ''horn they are referred. 

Section 1: -.IYj&L COLiPLAIhT'S SHALL ,_ rilhD 

Complaints of violations /of the Ladies' Handbag Industry Code 
must' b< [file* , in the first instance, with the appropriate Divisional, 
SubrDivision, 1; or Regional Complaints Committee, and if such complaints 
are sent ori inally to pni r other a;encies, they shall be forwa,rdecJ 
promptly to the ap iropriate body. Complaints sent direct to the 
Ladies' Handbag Industry Code Authority office in Hew York City shall 
be referred immediately to the ;?ropoer Divisional, Sub-Divisional or 
Regional Complaints Committee. 

Section 5: ho thin, herein shall irevent sn complainant - t any time 
from a opealin to the rational Hecovery ACiiinistration which shall 
have authorit; , in its discretion, to refer such complaints to a 

9811 



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higher agency of the Ladies' Handbag Industry Code Authority with a 
representative or representatives of the National Recovery Administration 
included therein, or to the Ladies' Handbag Indsutry Code Authority, 
or to other Compliance Agencies of tiie National Recovery Administration. 

Section 6: INFORMATION NOR ALKSfl SD VIOLAT ORS 

The Ladies' Handbag Industry Code Authority'-, shall prepare immediately 
a statement entitled "Information for persons charged with violation 
of an iJRA Code". This statement shall ret forth clearly the rules of 
procedure in respect to alleged code violations, and indicate that the 
alleged violator is entitled to hearing and to appeal from any findings 
made b - "- a Complaints Committee. The statement must also indicate the 
process by which a case of code violation reached the National Recovery 
Administration and the various courses of action which may be taken 
thereon by the Administration. 

Section 7: PROCEDURE ON DIVISIONAL AND SUB-DIVISIONAL COL'PLAINTS 
C0MU1TTZ5S II' HANDL ING- CO! PLAINTS : 

a) Immediately upon their receipt by Divisional, Sub-divisional 
or Regional Complaints Committees, complaints will be examined by the 
staff thereof, and when such preliminary examination indicates that the 
facts alleged, if true may constitute a violation of the Code, the 
complaint shall be filed and given a. complaint number. Acknowledgment of 
the complaint, and advice concerning the complaint number shall be sent 
immediately to the complainant. In the event that the complaint does not 
state sufficient facts to constitute a violation, or that additional 
facts are necessarv for determination whether the Code has been violated, 
complainant shall be required to furnish additional information. 

b) Where a complaint is obviously "crank" it shall be 
acknowledged and without further action placed in the file. Where 
complaint states facts which even if true would not constitute a 
violation of the Code, acknowledgment shall be ma.de to complainant 
with notice of rejection, accompanied \>y a brief explanation of the 
reasons therefor, 

c) Where a complaint has been accepted and all necessary facts 
have been secured from complainant, it shall be assigned to a. staff, 
member for inquiry and investigation. The first step in such inquiry 
and investigation is the preparation of a brief statement of the alleg- 
ed facts for transmission to the respondent, advising him of the 
Article of the Code alledged to be violated, and making reouest for 
prompt advice as to whether all or Dirf of the facts alleged are true, 
and a further statement of the position of the respondent. Respon- 
dent shall also be furnished with a copy of the Code and of "Information 
for Persons charged with Violation of the Ladies' Handbag Industry Code". 

Section 8: ADI.IISSION OP VIOLATION 



If respondent admits violation of Code, but indicates he is 
willing to comply in the future and has ma.de restitution for past 



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-513- 
vRsTat'ions, 'complainant shall be notified, of sixch adjustment. 

Section 9: nELTI.tL OF VIOLATIO N 

If the respondent denies the frets as alleged, or if he admits the 
frets but takes issue as to the meaning of the Code, or if he asserts 
that he is not subject thereto, or that there is a conflict of codes, 
or if the respondent falls to satisfy the Complaints Committee that he 
is not violating the Code, he should be notified to appear at the office 
of the Divisional Sub-Divisional or Regional Complaints Committee and 
state his case, when such an interview seems expedient and likely to 
facilitate an adjustment. If no interview is held, or if after such 
interview the case is still unadjusted, and it appears desirable for a 
field agent to visit the respondent, arrangements for such a visit shall 
be made. The field p ;ent, in addition to securing evidence shall seek 
to brin^ about an .adjustment with the respondent if it appears warranted. 
If efforts of staff members and field agents are unsuccessful in 
'securing said, adjustment, the complaint shall be set for hearing before 
the proper Complaints Committee and both the Complainant and respondent 
shall be notified thereof by registered mail. If, after such hearing, 
the complaint is still unadjusted and further facts or further inter- 
views .appear likely to facilitate adjustment, arrangements may be made 
to have a field agent visit the respondent. In case of doubt as to the 
meaning of the Code, or as to other facts, an official ruling shall be 
obtained from the appropriate source. 

Section 10: FAILURE TO RESPOND 

If respondent fails to answer communication addressed to him 
within five business days a second communication asking for a reply 
within five business days shall be sent him by registered mail. There- 
after if no reply has been received, or in any case if respondent indi- 
cates his unwillingness or lack of intention of complying, or of 
making restitution, the case shrll be assigned to a field agent for 
such further investigation as may be necessary to determine the facts 
of the case at first hand. 

Section 11: REFEREd'CIT, 0? CASIS TO EIC-IHR T30IIES 

a) After a Divisional, Sub-Divisional or Regional Complaints 
Committee has exhausted all reasonable efforts in adjusting my com- 
plaint through interviews, hearings, field, investigations, etc. , ajid. 
the complaint is still unadjusted, it may be referred to the appropri- 
ate National Complaints Committee, together with recommendations for 
further action. If rray any time any Complaints Committee is convinced 
that n complaint conclusively sets forth a violation which the respon- 
dent shows no disposition to correct or to adjust, such complaint may 
be immediately referred, together with the entire report, to the National 
Complaints Committee without following through the regular prescribed 
routine, arid the National Complaints Committee shall refer it promptly 
to the National Recovery Administration. 

b) Cases sent by a Complaints Committee to a higher body 
for iurther action must include the following data,; 



-514- 

(r) The origin- 1 complaint rnC, digest of the cr.se. 

(b) All previous Gforrespondence on the cr.se, 

(c) All origin- 1 evidence, including affidpvits ■ nd 
reports of field ag< iits, 

(d) Recommendations of the Coi.iplir.nce Committee. 

(e) Statements made by th< rtj'jj)ondent at herrings 
or interview, rnd pay '.written statements filed 
b; him. 

(f) A report of the Compl; ints Committee that 
respondent was furni shed with notice of the 
complaint rnd ma explanrtion of his obligations 
in ri Bo-, ct to the subject matter of the com- 
plaint; r copy of the Code; a copy of the 
Ladies 1 Handbag Industry Code information for 
persons charged with Violations of the ^ode; 

p. summary of the frets v/ith reference' to the 
violations found by the Complaints Committee, 
rnd any other pertinent facts. 

Respondent mur;t p.lso bt notified 01 reference of .°ny complaint 
p.gpinst him to ■■ higher body for further ; ction. 

Section 12: PROCEDURE FOP. KAIOhlUG- COI.iPUAIUTS BY NATIONAL COMPL AI ITT S 

COuNITTEE . 

a) Upon receipt of a complaint referred to it by Divisional, 
Sub- divisional or Regional Committee, or the National Trade Practice 
Complp.int'5 Committee or the National Labor Complaints Committee, as 
the case nay be, shall so notify the. complainant pad respondent. 

The respondent shall be advised rfter pppropriate exrmination of the 
complaint that unless he has additional facts to submit or unless he 
desires a re-hearing the case will be referred to the National Recovery 
Administration with - request for legrl action. 

b) If the respondent replies thr-t proper adjustment has been 
made the case shall be referred back to the Complaints Committee -where 
it originated. If respondent submits further facts, or requests a 
further hearing, the cp.se shall be docketed for hearing oy the Execu- 
tive Secretary of the National Complicate Committee. If rfter the 
hep.ring the respondent fails to comply v/ith the adjustment prescribed 
by the National Complaints Committee, or if at rr^ time the Committee 
is convinced that the respondent shows no disposition to correct or 
adjust the case, it shall be referred to the Nr.tional Recovery Adminis- 
tration together with - summary of such recommendations as the Committee 
mpy desire to make. 

c) Either party to r case shall have an unrestricted right 
of appeal to UFA from the findings of the Nptional Gommittee. The 
n,-mes pad parties to the cases and all f r cts pertpining thereto shall 
be kept confidential. 

Section IS: POUER OF UOLIFICATION OR ABOLITION OF SUBORDINAT E 
AGENCIES . 

The Code Authority shall have the power to remove any member 

3811 



-515- 

or members of any subordinate rgency vhose appointment or election 
rests with the Code Authority, or to modify the functions or to abolish 
entirely any agency, the creatio:. of which rests with the Code Authority, 
if, in the judgment of the Coat Authority, such action will promote 
just and efficient administration of any code function; provided that in 
no event shall the Code Authority have the power to remove anji represen- 
tatives of labor or Labor Comply ints Committees. 

Section 14: 5XP51 T SZS 0? COI Ihl TTIiZ: r lPhBIRS. 

a) "ilrtio-i-l Trade Practice Somplaints Committer . 

The expenses of the membersof this Committee shall be paid by the 
Ladies' Handbag Industry Code Authority on a mileage and per diem V.sis 
equrl to that paid to the members of the Ladies' Kandbn Industry Code 

Authority. ■ 

b) Divisional -:id Subdivision.-l Trade Prrctice Complaints . 

Members of these Committees shall have their e:cpenses paid by the 
rppropriate Division or on the snme basis and in the same manner as 
other'.Oode Administrative Agency Committees in trie same Division or 
Subdivision. 

Section 15: liO'dTKLY ELPORTS TO II. R. A. OH COMPLAINTS . 

The Ladies' Handbag Industry Code Authority shall make montly 
reports to the national Industrial Recovery Board setting forth the 
number of complrints filed with it, the number of complaints adjusted 
by it, and the number of complaints which remained unadjusted, within 
e.-ch monthly period, classified ^s trade practice complaints. 



9811 



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EXHIBIT C-l 

Labor Cc .: laints Comnittee 



3811 



-517- 
EXHIBIT C- 1 



At a meeting of the Code Authority held at the HcAlpin Hotel on June 14, 
1934- the f ol lowing resolution was made, seconded and unanimously adopted: 

RESOLVED 

"That the Code Authority be, and is hereby authorized 
to appoint a National Labor Complrints Committe con- 
si stmj of three members; 

That the Labor Advisory Board shall also appoint three 
members to this committee; 

That the Administration Member of the Code Authority 
shall be a member of this committee and 

That the committee shall have a paid secretary and a 
legal advisor; 

That the names of the members comprising this committee 
shall be- presented to the Code Authority at the next 
regular meeting." 



( Si gned ) Irving Schoenhclz 
Secretary 



Sworn to and subscribed before me 
) this 6th day of July, 1934 

(Signed) Eva Seligman 

Notary Public 
New Yoi-k County Clerks No. 185 

(SEAL) New York Co. Register No. 5-8-575 
Commission expires March 30, 1935. 



9811 



-518- 



At a meeting of the Code Authority held at the Hotel HcAlpin 
on J une 14, 1934 the names of the following members were 
suggested as members to serve on the National Labor Complaints 
Committee. Hie Code Authority voted approval. 



David A. Ingber 



David Mo rgen stern 



President In g"b or & Co., Inc. 
347 Fifth Ave. 
Hew York, N. Y. 

President Llorgenstern £ Brosseau, Inc, 
26 7/est 17th Street 
New York, N. Y. 



Sol l.iutterperl 



President 



Sol Llutterperl, Inc. 
330 Fifth Ave. 
New York, N. Y. 



( Signed) Irving Schoenholz 
Secretary 



Sworn to and subscribed before me 
this 6th day of July, 1954. 

(Signed) Eva Seligman 

Notary Public 



9311 



-519- 



July 11, 1934. 



Mr. 0. 1. Pearson 
45 Broadway 

New York City 



Bear Lir. Pearson: 

In addition to the three Industry 
members of the National Labor Complaints 
Committee, there shall be three labor members 
of said Committee to be designated by the 
Labor Advisory Board of the National Eeccvery 
Administration. 



Very truly yours, 



(Signed) A. Mitt en thai 
A. Mitten thai, 
Code Director, 
Ladies' Handbag Code 
Authority 



9811 



-520- 

code authority 
ladies; handbag industry 

347 ^ Fifth Avenue 
KEV/ YORK 

July 6, 1934. 

REPORT TO THE NATIONAL RECOVERY ADMINISTRATION OF THE ADi.ilNI STRATI ON 
UMBER OE THE CODS AUTHORITY FOR THE CODE 07 PAIR COMPETITION FOR THE 

LADIES' HANDBAG INDUSTRY 



Dean G. Edwards 
Deputy Administrator 
Apparel Section, Division 5 
National Recovery Administration 
Washington, D. C. 

Dear Mr. Edwards: 

Tlie Code Authority of the above Code of Pair Competition 
desires to qualify as a Labor Complaints Committee in the first in- 
stance for tHe purpose of receiving and adjusting all labor complaints 
of violation arising in the Industry. 

It is the desire of the said Code Committee that it 
create itself as a Complaints Committee. 

The groups and interests represented by each member of the 
Code Authority functioning as a Complaints Committee are as follows: 



NALiE: David A. Ingber 



President 



Ingber and Co., Inc. 
547 Fifth Avenue, 
New York, N. Y. 



OCCUPATION: Manufacturer of Ladies' Handbags 
REPRESENTING: Ladies' Handbag Industry 



NAME: David Morgenstern 



* * * 
President 



liorgenstern C: Brosseau,Inc, 
26 West 17th Street 
New York, N. Y. 



OCCUPATION: Manufacturer of Ladies' Handbags 
REPRESENTING: Ladies' Handbag Industry 

* * * 



SAME: 



Sol Hutteroerl 



President 



Sol Mutterperl, Inc. 
330 Fifth Avenue 
New York, N. Y. 



OCCUPATION: Manufacturer of Ladies' Handbags 

REPRESENTING: Ladies' Zrxic&r^ Industry 



* * * 



9811 



-■'"l^l — 



Dean G. Edwards 

The business address of the NATIONAL LAI3CR COMPLAINTS 
COMMITTEE is, and will continue to be: 

347 Pi f tli Avenue, 
New York, N. Y. 

The exact scope of the said Complaints Committee will 
be the territory embraced by the Code of Fair Competition for the 
above-named Industry. 

It is desired that complaints within the scope of said- 
Code Authority -".re to bs filed in the first instance with the said 
Code Authority. 

The said Complaints Committee insofar as it?: Industrial 
Adjustment Agency is concerned, is to deal with complaints of alleged 
violations which refer respectively to: 

(1) Labor provisions (when the complaint alleges that an employer 

is violating a labor provision and is 
handled as a fair trade practice complaint) 

(2) Hours of labor (when the complaint alleges that an employer 

is violating an hour provision and is 
handled as a fair trade practice complaint) 

(3) Minimum Wages (when the complaint alleges that an employer 

is violating a wage provision and is 
handled as a fair tr.de practice complaint) 

The Code Authority has been duly and properly constituted 
and has been functioning satisfactorily since the effective date of 
said Code; it is well equipped financially to undertake the expense 
of the functioning of the said Complaints Committee and is particularly 
desirous, in the interest of strict compliance with the Code and the 
principle and spirit of the National Industrial Recovery Act, to place 
trustworthy investigators in the field to the end that each unit of 
the Industry may be brought to a complete knowledge that this Code and 
the Act itself are to be observed, supervised and properly enforced. 

Any change in the said committee, either in personnel 
or in the establishment of regional Complaints Committees, will be 
immediately reported to the Na.tional Recovery Administration. 

Respectfully submitted, 

(Signed) C. V7. Pearson 



Admini s tration Llemb er 



9811 



-522- 

CODE AUTI-IOSITY 
LADIES' EAND3AG INDUSTRY 
347 FIFTi: AVENUE 
Hew York 



July 6, 1934. 

Mr. 0. W. Pearson 
45 Broadway 
New York City 

Dear Lir. Pearson 

It is the aim and purpose of the Code Authority of the Ladies' Handbag 
Industry to secure compliance with the previsions of the Code by all 
persons subject to its jurisdiction, without resort of legal process; 
and to avoid calling in governmental aid until the Code Authority 
agencies have exhausted all reasonable efforts at securing compliance 
otherwise. 

The Code Authority has organized a Rational Labor Complaints Com- 
mittee consisting of not less than six members, three of which have 
been appointed to represent employers by the Code Authority. The Ad- 
ministration Member of the Code Authority shall be a member of this 
committee. Ue shall also have a full time paid executive secretary 
and a legal advisor. The names and interests represented by each 
member of the National Labor Complaints Committee are as follows: 

David A. Ingber, President Ingber d Co. Inc. 

347 Fifth Ave. , N.Y. 

David horgenstern President I.Iorgenstern d Brosseau, Inc. 

26 W. 17th Street, N." Y 

Sol Mutterperl President Sol Mutterperl, Inc. 

330 Fifth Ave. , N. Y. 

The business address of the National Labor Complaints Committee is, 
and will continue tc be, at 347 Fifth Avenue, Hew York, N. Y. 

The Code Authority is duly and properly constituted and is function- 
ing satisfactorily since the effective date of said Code March 26, 
1934; it will be equipped financially to undertake the expense of the 
functioning of the said Complaints Committee, and is particularly de- 
sirous in the interest of strict compliance with the Code and the 
principle and spirit of the National Industrial Recovery Act, to 
place trustworthy investigators in the field to the end that each 
unit of the industry may be brought to a complete knowledge that this 
Code and the Act itself are to be observed, supervised and properly 
enforced. 



9811 



-523- 



Lir. Pearson: - 



Any change in the said Committee, either in personnel or in the 
establishment of regional Complaints Committees, will be immediately 
reported to the National Recovery Administration. 



.Very truly yours, 

CCDE AUTHORITY 
ladies' ::andbag INDUSTRY 



( Signed) A. Mitten thai 
A. Mitten thai 
Code Director 



( Signed) Irving Schoenholz 
Secretary 
am: edl 



Sworn to and subscribed before 
me this 6th day of July, 1934 

(Signed) Eva Seligman 
Notary Public 



9311 



-524- 



Mr. G. W. Pearson 
45 Broadway- 
New York City- 



Dear Mr. Pearson: 

In Addition to tie three Industry 
members of the National Labor Complaints 
Committee, there shall "be three labor members 
of said Committee to be designated by the 
Labor Advisory Board of the National Recovery 
Administration. 



Very truly yours, 



( Signed) A. Hit ten thai 

A. Mitten thai 
Code Director, 
Ladies' Handbag Code 
Authority. 



9811 



-525- 

COUPLIMCE JUMIHIS1RAIEIGH 
for the 

CODE OF FAIR COMPETITION 

of the 
LADIES' HANDBAG INDUSTRY 



ARTICLE I. ORGANIZATION OF LABOR COMPLAINTS COMMITTEE 

Section 1: Creation cf National Labor Complaints Committee 

The Code Authority shall establish a National Labor 
Complaints Committee consisting of not less than (4) or more than 
(10) members, one-half of which shall represent employers and shall 
be appointed by the Code Authority, or by its presiding officer; end 
one-half of v/hich, representing employees, shall be appointed by the 
President on recommendation of the Labor Advisory Board of the Nation- 
al Recovery Administration. An Administration Member of the Code 
Authority shall be a member of this Committee. He shall have no vote 
but a veto subject to review by the Administrator. The Committee 
shall have a full-time paid Executive Secretary, who shall be on the 
staff of the Ladies' Handbag Code Authority and may devote part of 
his time to Code Authority duties other than those of this Committee. 
The Committee shall also have a legal adviser. 

Section 2: Administrative Personnel of National Labor Complaints 
Committee . 

The Committee shall elect from its members a presiding 
officer to preside at all meetings, but such person shall retain and 
exercise the right to vote. The Committee shall also elect an 
arbitrator who shall be called to serve as presiding officer with 
right to vote when- the Committee is evenly divided on any question. 
The Committee, subject to disapproval of the National Recovery Admin- 
istration, shall adopt its own by-laws and rules of procedure, and 
fix the time and place of regular and special meetings, and the 
manner in which such meetings shall be called and conducted. The 
by-laws, with respect to a. quorum, shall provide for equal voting 
representation of employee and employer members. The facilities of 
the Code Authority as to necessary office space, stenographic and 
clerical help, and place of meeting, shall be made available to the 
Committee. The Executive Secretary of the Committee, shall report at 
all meetings thereof a summary of the cases handled by the staff in 
the intervals between meetings together with a statement indicating 
disposition cf cases closed. 

Section 3: Functions of National Labor Comp lain ts Committee (or 
Industrial Relations Committee) 

a) The National Labor Complaints Cc.ouiittee shall have juris- 
9811 



-526.- 

diction in the first instance over all complaints alleging violation 
of Articles III, IV and V which refer respectively to (l) Hours of 
Labor and (2) Minimum "Jages of the Ladies' Handbag Industry Code, and 
(3)vLabor Provisions, and in the conduct of its work may recommend 
to the national Recovery Administration, through the Executive Officer 
of the Code Authority, temporary exceptions to and temporary ex- 
emptions from the provisions cf the Code, and may make such explana- 
tions and expositions and interpretations cf Code provisions as its 
work may reouire. The Executive Officer shall forward to tie Nation- 
al Recovery Administration not later than the day after receipt and 
without change, all recommendations of the National Complaints Com- 
mittee made pursuant to the provisions of this paragraph. 

b) The Committee shall issue regulations clearly defining its 
relations with t_e regional complaints committees hereinabove provided, 
and is empowered to alter the powers, duties, and territorial juris- 
diction of regional labor complaints committees to change the number 
--------------- — ______ __ c f sue. committees, 

and the number of its members as circumstances may require, to issue 
regulations and instructions, to require such reports as may be nec- 
essary to make these rules effective, and keep the Committee and the 
National Recovery Administration fully advised concerning labor com- 
pliance work under the Ladies' handbag Industry Code. 

Section 4: Regional Labor Complaints Committees 

The Code Authority shell establish Regional Labor Com- 
plaints Committees for the various parts of the United States, and 
designate the jurisdiction of such Regional Labor Complaints Com- 
mittees, their locations and their methods of expense distribution, 
which shall apply to all persons subject to the Code located in the 
territory included under the jurisdiction cf such Regional Labor 
Complaints Committees. 

Section 5: Membership of Regional Labor Complaints Committees 
(Regional. Industrial Relations Zo- irdttees ) 

(a) For each sue! 1 . Regional Labor Complaints Committee, 

one-half of the membership, representing employees, shall be 
appointed by the National Recovery Administration on recommendation 
of the Labor Advisory Board of the National Recovery Administration. 
The members representing employers shall be appointed by the Code 
Authority from a panel including persons nominated by the Divisions 
affected, so as to give fair representation to all Divisions. 

(b) Each such Committee shall elect a Chairman, who 
shall retain and exercise the power to vote. Said Committee shall 
also elect an arbiter who shall serve, with right to vote, when the 
committee is equally divided on any question. 

Section 6: FUNCTIONS OF REGIONAL LABCRCC. PLAINTS CCl.u.iITTESS (or 
iECIhllAL INDUSTRIAL RSLATIhTS OhhlTTNES . ) 

The Regional Labor Complaints Committees subject to ap- 



9811 



-527- 

proval of the National Labor Complaints Committee, shall adopt "by-laws, 
and rules of procedure, and shall make provisions therein for periodic 
meetings raid herrings at various places in the territory subject to 
their jurisdiction so as to give reasonable opportunity for the com- 
plainants and respondents to appear before the Committee. The by-laws 
may also provide for the conduct of hearings and interviews by sub- 
committees on which there shall be eo L ual representation of members 
representing employees and memoers representing employers. 

Section 7: DELEGATrrN OF FCTSHS BY REGIONAL LABOR COhPLAINTS CON - 

uittses or regional industrial relations coni.iittbes . 

Any Regional Labor Complaints Committees may, by agree- 
ment approved by the national Labor Complaints Committee, delegate 
a portion of its powers or transfer a portion of its jurisdiction tc 
any other Regional Labor Complaints Committee when such delegation . 
and transfer is in the interest of better administration or appears 
likely to facilitate and improve compliance work. 

Section 8: APPORTIOIN.OENT OF EXPOSES 3ET.7ESN AGENCIES OF THE 
CODE AUTHORIT Y. 

Each Regional Labor Complaints Conmiittee shall pro-rate 
the expense of handling labor complaints and/ or labor disputes among 
the Divisions under its jurisdiction in such amount and in such 
manner that each Division, Subdivision, and Group concerned shall 
bear its proportionate and jjust share of the total expense of said 
Regional Labor Complaints Committe. 

Section 9: APPROVAL OF PERSONNEL OF LABOR CCiPLAINTS COUUITTESS 
BY LABOR .iDVISORY BOARD 

The Labor Advisory Board cf the N. R. A. shall approve 
the selection of all representatives of labor, who may be selected 
in accordance with procedure herein provided, for service on any 
labor Complaints Committees and/or Industrial Relations Committees, 
if, and when created. 

ARTICLE II. GENERAL FACILITIES OF Ch PLAINTS CChhITTEES 
Section 1: DEPARTLENT OF COLiPLlANCE. 



The Code Authority may create an executive organiza,- 
tion to be known a.s the Department of Compliance headed by a Chief 
of Compliance, which Department sha.ll have general administrative 
supervision over all National, Divisional, and Subdivisional com- 
pliance activities of the Code Authority. 

Section' 2: EL1PLCYKSNT OF FIELD AGENTS AND OFFICE AS SI STMTS . 

Divisional and Subdivisional Trn.de Practice Complaints 
Committees and Regional Labor Complahnts and/or Industrial Relations 
Committees shall request from the appropriate Division cr Subdivision 
agency such staff assistance as it may require and such a.ssi stance 
shall be furnished promptly. 7Jh.il e engaged in assignments for Com- 
pliants Committees such staff shall be under the instructions and 

9811 



-528- 

direction of the Committee and shall "be responsible thereto. Whenever 
necessary agents may be celled to testify at hearings en cases arising 
under the jurisdiction of the agency by whom they are employed. 

Section 3: FUNCTIONS AND DUTIES OF FIELD ASSETS AND STAFF El.iPLCYEES . 

a) It is the primary purpose of field agents to determine 
the facts, to explain tc persons subject to the Code their duties, 
their rights and obligations, and to attempt by tact and persuasion 
to secure an amicable adjustment of complaints. In cases where re- 
spondent admits facts as alleged in a complaint the field agent 
should obtain his explanation and a statement from him as to what he 
will do to make restitution for violations admitted by him. If re- 
spondent admits fact? as alleged but takes issue as to the application 
of the Cede to these facts, the field agent shall obtain a clear 
explanation of the reasons for his position. If respondent denies 
facts, the field agent shall ash permission to examine records but 

if such permission is refused he shall not insist upon access to 
such records. He should, however, explain to respondent that his re- 
fusal will be an indication that he does net desire to adjust the 
complaint and will operate to his disadvantage. 

b) Before investigating e.n alleged violation, field a- 
gents shall notify respondent of the approximate date of arrival and 
the purpose of their visit. Employees should not be interviewed dur- 
ing working hours or upon the premises of the respondent unless per- 
mission to do so has been obtained. from the latter. Field agents 
should bear in mind at all times that it is their function to find 
the facts and explain respondent' s obligations under toe Code. They 
should not engage in argument or dispute. Their reports should be 
made only to the appropriate Complaints Committee for further action. 

c) The Committees shall promptly advise the Code Auth- 
ority or its agencies of. any cases in which persons subject to the 
Code have failed to permit field agents of the committees to visit, 
examine, or otherwise investigate conditions in any establishment 
operated by them, and the Code Authority and its agencies shall give 
similar information to the Committees. 

Section 4: FIELD AGENT 1 S 2EPCRTS . 

If a field agent reports that respondent has not violated 
any provisions of the Code, complainant will be so advised, and if no 
further word is received from him within a reasonable time the case 
shall be closed and the respondent so advised. If agent's report in- 
dicates that respondent is willing to comply and make restitution for 
past violations, upon satisfactory evidence that such action has been 
talc en, axlvice shall be given both to respondent and to complainant 
and ca.se shall be closed. If agent reports that respondent refuses 
to comply or make restitution, or has failed to furnish satisfactory 
explanation and it is decided that further attempts to adjust com- 
plaint will be futile respondent shall be advised that the case has 
been transmitted for a.ction to the proper National Complaints Com- 

9811 



r529r. 



mittee of tlie Code Authority . 

Section 5: DISSATISFACTION WITh FIJLD AGEPT' " HEP OPT . 

If either the complainant or respondent is dissatisfied 
witli Field Agent's report, tiiey shall have the right to appear be- 
fore tie appropriate Complaints Committee in person or to file a 
statement with the Committee stating such new or additional facts 
as they may feel are pertinent to the case. 

Section 6: STATEiEPT hY PESPCPDENT . 

Whenever a respondent makes a statement in a hearing or 
in an interview, a statement thereof should be promptly prepared by 
the Executive Secretary of the Complaints Committee. Such statement 
should be signed by respondent if he is willing; if he declines to 
sign it, the summary should so indicate; if respondent declines to 
made any statement, the recommendations of the Complaints Committee 
should so indicate. 

APT I CLE III. PROCEDURE IP ThE hAuDLIITG OF COhPLAIPTS 

Section 1: . DEPIIIITIGh 'IP COhPLIAPOE . 

Compliance as used herein includes: 

a) Bie instruction and education of persons subject to the 
Code concerning their responsiblities thereunder so as 
to anticipate and avoid complaints of non-compliance; 

b) Tlie adjustment of complaints of non-compliance by educa- 
tion, findings of fact, and pressure of opinion within 
tiie industry; 

c) The adjustment of complaints by conciliation, mediation 
and arbitration; 

d) The rendition of reports to enforcement agencies of the 
government in cases where all other means have failed. 

Section 2: DEFIPITICP CF LABCP CGhPLAIITTS . 

By labor Co.. plaints for purposes of these regulations shall 
be understood only these complaints which allege violations of labor 
provisions (Articles III, IV, V) of the Code, which Articles refer re- 
spectively to (l) Hours of Labor, (2) hinimum Wages, and (3) Labor 
Provisions. 

Section 3: POEM ^F COMPLAINTS. 



Complaints of code violations must be filed in writing, 
preferably on the standard form approved by the Code Authority, copies 
of .which may be obtained from any agency of the Code Authority. 

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-530- 

Anonymous complaints will be acted upon only in the discretion of the 
Complaint Committee receiving such complaint. 

Section 4: COiTHiJU^lAl ^HARACTIR OF COMPLAINVS 

The name of the complainant on labor complaints must be kept 
confidential and the fact that a connlaint has been filed against any 
person under the Code alleging violation of other provisions of the 
Code must also be kept confidential. 

Section 5: OTH5RI COi PLAINTS SHALL 3E FILED . 

Complaints of violations of the Ladies' Handbag Industry Code must 
be filed, in the first instance, with the appropriate Divisional,' Sub- 
divisional, or Regional Complaints Committee, and if such complaints are 
sent originally to any other agencies, they shall be forwarded promptly 
to the appropriate body. Complaints sent direct to the Ladies' Handbag 
Industry Code Authority office in Few York City shall be referred 
immediately to the proper Divisional, Sub divisional or Regional Complaints 
Committee. 

Section 6: 

ITothing her -in shall prevent v:iy complain, nt at any time from 
appealing to the National Recover;- Administration which shall have 
authority, in its discretion, to refer such complaints to a higher 
agency of the Ladies' Handbag Industry Code Authority with a representa- 
tive or represent,- tives of the National Recovery Administration included 
therein, or to the Ladies' Handbag Industry Code Authority, or to 
other Compliance A.encies of the National Recovery Administration. 

Section 7: Inf ormation for Alleged V iol ators. 

The Ladies' Handbag Industry Code Authority shall prepare immediate- 
ly a statement entitled "Information for persons charged with violation 
of the ladies' Handbag Industry Code." This statement shall set forth 
clearly the rules of procedure in respect to alleged code violations, 
and indicate that the alleged violator is entitled to hearing and to 
appeal from any findings made by a Complaints Committee. The statement 
must also indicate the process by which a case of code violation reached 
the National Recovery Administration and the various courses of action 
which may be taken thereon by the Administration. 

Section 8: Procedure of Divisional and Subdivisional Complain ts 
C oiimittees in Handlin^ Complaint s. 

a) Immediately upon their receipt by Divisional, Subdivisional, 
or Regional Complaints Committees, complaints will be examined by the 
staff thereof, and when such preliminary examination indicates that 
the facts alleged, if true may constitute a violation of the Code and 
complaint shall be filed and given a complaint number. Acknowledgement 
of the Complaint, and advice concerning the complaint number shall 
be sent immediately to the complainant. In the event that the complaint 
does not state sufficient facts to constitute a violation, or that 
additional facts are necessary for determination whether the Code has 

9811 



been violated, complainant shall be required to furnish additional in- 
formation. 

b) Where a complaint is obviously "crank" it shall be acknowledged 
and without further action placed in file. Where complaint states facts 
which even if true would not constitute a violation of the Code, acknow- 
ledgement shall be made to complainant with notice of rejection 
accompanied by a brief explanation of the reasons therefor. 

c) Where a conrolaint has been accepted and all necessary facts 
ha.ve been secured from complainant, it shall be assigned to a staff 
member for inquiry and investigation. The first step in such inquiry 
and investigation is the preparation of a brief statement of the alleged 
facts for transmission to the. respondent, advising him of the Article 

of the Code alleged to be. violated, and maltin, request for prompt 
advice as to whether all or any of the facts alleged are true, and a 
further statement of the nosioion of the respondent. Respondent shall 
also be furnished with a copy of the Code and of "Information for 
Persons charged with Violation of the Ladies' Handbag Industry Code". 

Section 9: Admission of Violation . 

If respondent admits violation of Code, but indicates he is willing 
to comply in the future and has made restitution for past viol- tiens, 
complainant shall be notified of such adjustment. In the case of an 
employee who has been discharged for filing a complaint reemployment 
and restitution of any lost v;a & es, must be a condition precedenlv-to 
adjustment. " 

Section 10: Denial of Violation . 

If the respondent denies the facts as alleged, or if he admits the 
facts but tdEs issue as to the meaning of the Code, or if he asserts 
that he is not subject thereto, or that there is a conflict of codes, 
or if the respondent fails to satisfy the Complaints Committee that 
he is not violating the Code, he should be notified to appear at the 
office of the Divisional, suodi visional or Regional Complaints Committee 
.and state his case, when such an interview seems expedient and likely 
to facilitate an adjustment. If no interview is held, or if after 
such interview the ca.se is still unadjusted, and it a'-nears desirable 
for a field agent to visit the respondent, arrangements for such visit 
shall be made. The field agent, in addition to securing evidence shall 
seek to bring about an adjustment with the respondent if it appears 
warranted. If efforts of staff members and field agents are unsuccessful 
in securing said adjustment, the complaint shall be set for hea.ring 
before the proper Complaints Commit cc- and both the complainant and 
respondent shell be notified thereof. If, after such hearing, the 
comnlaint is still unadjusted and further facts or further interviews 
appear likely to facilitate adjustment, arrangements may be made to 
have a field a fa ent visit the respondent. In case of doubt as to the 
meaning of the Code, or as to other facts, an official ruling shall 
be obtained from the a/riropriate source. 

Section 11: Failure to Respond 



9811 



If respondent fails to answer comimni cation addressed him within 
a reasonable time a second communication asking for reply within a 
stated period shall be sent him by registered mail. Thereafter if no 
reply has been received or in any ca.se if respondent indicates his 
unwillingness or lack of intention of conniving, or of making restitution, 
the case shall be assigned to a field agent for such further investiga- 
tion as may be necessary to determine the facts of the case at first 
hand. 

Section 12: Hearings on Cony 1-i.its Involving Labor Complaint's . 

Hearings on all complaints involving both trade practice and 
labor complaints shall be conducted by Labor Complaints Committees 
subject to the following provisions: 

1. A member of the Trade Practice Complaints Committee of the 
Division or Subdivision under whose jurisdiction the complaint has 
arisen shall sit on the Labor Complaints Committee. but shall not be 
entitled to vote on labor questions. 

Section 13: Referenc e of Cases to Hi. .her "Jodies . 

a) After a Divisional, Sub divisional, or Regional Complaints 
Committee has exhausted all reasonable efforts in adjusting any complaint 
through interviews, he rings, f ield^investi. at.ions, etc., and the 
complaint is still unadjusted, it may be referred to the appropriate 
National Complaints Committee, together with recommendations for 
further action. If at any time any Complaints Committee is convinced 
that a complaint conclusively sets forth a violation which the respond- 
ent ..hows no disposition to correct or to adjust, such complaint may 

be i.. Mediately referred, together with the entire report, to the 
National Complaints Committee without following through the regular 
prescribed routine, and the rational Complaints Committee shall refer 
it promptly to the National Administration. 

b) Cases sent by a Complaints Committee to a higher body for 
further action must include the following data: 

a) The ori. ina.l complaint and digest thereof. 

b) All previous Correspondence on the case. 

c) All originaJ evidence, including affidavits and reports 
of field agents. 

d) Recommendations of the Complaints Committee. 

e) Statements made by the respondent at hearings or inter- 
view, and any written statements filed by him. 

f) A report of the Complaints Committee tha.t respondent was 
furnished with notice of the complaint and an explanation 
of his obligations in respect to the subject matter of 
the complaint; a cop;/ of Che Code; a copy of the Ladies' 
Handbag Industry Code information for persons Charged 
with Violations of the Code; a summary of the facts with 
reference to the violations found by the Complaints 

'Committee, and any other pertinent facts. 

Respondent must also be notified of reference of any complaint against 

him to a higher body for further action. 

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-533- 

Section 14: Procedure for Kandli:y. Complaints by rational Complaints 
Committee . 

a) Upon receipt of a complaint referred to it by Divisional, 
Sub divisional, or Regional Connlaints Committees, the rational Labor 
Complaints Committee shall -r.o notify the complainant and respondent. 
The respondent shall be advised after appropriate examination of the 
complaint chat unless he has additional facts to submit or unless he 
desires a re-hearing the case will be referred to the National Recovery 
Administration with a roouest for legal action. 

b) If the respondent replies that proper adjustment has been 
made the case shall be referred back to the Connlaints Committees where 
it originated. If respondent submits further facts, or Bequests, a 
further hea.rin , one case shall be docketed for hearing by the 
Executive Secretary of the "rational Complaints Committee. If after the 
hearing the respondent fails to comply with the adjustment prescribed 
by the national Complaints Committee, or if at any time the Committee 
is convinced that the res londent shows no disposition to correct or 
adjust the case, it shall be referred to the rational Recover;- Admin- 
istration together with a summary of such recommendations as the 
Committee may desire to make. 

Section 15: Pow er of Modification or Abolition of S ubor dinate Agencies . 

The Code Authority shall have the power to remove any aember or 
members of any subordinate agency whose a jpointment or election rests 
with the Code Authority, or to modify the functions or to abolish 
entirely eray agency, the creation of which rests with the Code Authority, 
if, in the judgment of the Code Authority, such .action will promote 
just and efficient administration of any code function; provided that 
in no event shall the Code Authority have the power to remove any . 
representatives of labor or Labor Complaints Committees. 

Section 16: Expenses of Committee Ilembers . 

a) National Labor Complaints Committee. 

The expenses of the :embers of these committees shall be paid by 
the Ladies' Handbag Industry Code Authority on a mileage and per diem 
basis equal to that paid to the members of the Ladies' Handbag Industry 
Code Authority. 

b ) Regional L ab or Com >!,- jnts Committee . 

Members of these Committees shall have their expenses paid by 
the Division or Subdivision agency where headquarters are maintained, 
on the same oasis and in the same manner as other Committees of the 
Division or Subdivision Agency where headquarters s.re maintained. 

Section 17: Weekly Reports to P.R.A. on Complaints . 

The Ladies' Handbag Industry Code Authority shall make weekly 
reports to the administrator settin_ forth the number of complaints 

9811 



-534- 

f iled with it, the number of conrolaints adjusted by it, and the number 
of complaints which remained unadjusted, within each weekly -period 
classified as labor conrolaints, -provided that with the approval of 
the Administrator such weekly reports may be superseded by monthly 
reports within a reasonable time. 



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-535- 



X H I 3 I T D-l 



Constitution and By-Laws 



-536- 

CONSTITUTICM AND BY-LAWS 
CODE AUTHORITY 
FOR THE 
LADIES 1 HAUDBAG INDUSTRY 



ARTICLE I 



The Code Authority for the Ladies 1 Handbag Industry having been 
organized in accordance with the provisions of the Code of Fair 
Competition as approved by the President on Liarchl4, 1934, hereby 
establishes and publishes the following By-Laws: 

ARTICLE II 

Section 1. "Code" as used herein means the Code of Fair 

Competition for the Ladies' Handbag Industry as 
apT) roved "oy the President on March 14, 1934 to- 
gether with any additions to or modifications 
thereof, and includes all Executive Orders and 
rules and regulations which have been or may 
hereafter be made pursuant to Title I of the 
national Industrial Recovery Act (hereinafter 
referred to as the Act) by the President or Ad- 
ministrator relating to or affecting this 
Industry. 

Section 2. The definitions in Article II of the Code are 
made a part hereof. 

Section 3. "Due notice" as used herein means actual notice 
or notice by telephone or telegraph dispatched 
at least three days prior to the meeting or event 
for which notice is required. Actual attendance 
at such meeting or event, or a waiver of notice 
executed in writing or sent by telegraph either 
before or after such meeting or event shall be 
deemed equivalent to "due notice." 

Section 4. Definition of "IT.R.A." — "U.S.A. « as used herein 
means the National Recovery Administration. 



ARTICLE III 
Section 1. The Code Authority shall have the right to issue ceertifi- 



9811 



-537- 



cates of compliance. Agreement to comply with the Code 
shall be evidenced by signing these certificates in substan- 
tially the following form: 

The undersigned has read and fully understands the 
terms and conditions of the Code of Fair Competition 
for the Ladies' Handbag Industry adopted and approved 
by the Administrator for Industrial Recovery on 
March 14, 1934, and the Regulations adopted by the 
Code Authority Ladies* Handbag Industry pursuant 
thereto, approving upon Page Six (6) of this form; 
and agrees at all times to observe and comply with 
such Code and Regulrtions and any other regulations 
hereafter to be adopted by such Authority, and the 
undersigned understands that the right to use labels 
a-dopted and to be issued by this Code Authority shall 
be conditioned upon such compliance. 

The undersigned further agrees to furnish such in- 
formation and to submit to such investigations and 
inspections as the Code Authority Ladies' Handbag 
Indi\stry may prescribe to insure the faithful per- 
formance of the obligations assumed by the under- 
'■ signed as herein stated. 

The undersigned hereby applied to the Code Authority 
Ladies' Handbag Industry for labels adopted and to be 
issued by this Code Authority. The undersigned agrees 
that such labels, when and as issued, shall be attached 
only to handbags, oocl:etbool:s and purses manufactured 
by the applicant or for his account, and that such hand- 
bags, pocketbooks and purses shall be made under the 
terms and conditions prescribed in the Code and Regula- 
tions adopted pursuant thereto. 

The applicant understands that all handbags, pccketbooks 
and rurses manufactured by him or for his account shall 
bear such labels. This application shall apply to all 
labels to be issued by the Code Authority Ladies' Hand- 
bag Industry to the undersigned. 

Date 



Witnessed by 



Address of V/itness 



Address 



Lame of Corooration, Partnership or Individual 



Properly authorized officer or partner, (if cor- 
poration apply seal.) 

S3AL 



5311 



-538- 

Section 2. The Code is "binding on all members of the industry, 
irrespective of whether or not they agree to comply. 



ARTICLE IV 



Section 1. The Code Authority is an agency of limited powers and 
functions established under the authority of the National Industrial 
Recovery Act and by virtue of the Code. It shall consist of such 
number of Industry Members and Administration Members as may be pro- 
vided for in the Code. The Members of the Code Authority shall hold 
office for 12 months and such term shall b egin on March 26, 1934. 
Their successors shall be elected on March 1, 1935 but shall not 
take office until March 26, 1935. 

Section 2. Each group, entitled by the Code to select members to 
the Code Authority, shall select successors to the present members 
on or before March 1, 1935. Sacl: group shall certify and present 
to the Code Authority. 

1. A list of its members. 

2. The notice regarding the proposed selection 
of the successor members to the Code Autho- 
rity. 

3. The minutes of the meeting at which the 
selection was made. 

Section 3. Each group that has been authorized by the Code of 
Fair Competition to select representatives to the Code Authority, 
may also select an alternate or alternates. The alternate or al- 
ternates may attend meetings of the Code Authority, but shall not 
be entitled to participate or vote in the business of the meeting, 
unless such alternate cr alternates have been directed by the Chair- 
man of the meeting to take the place of the absent member or members 
of the group, which the alternate or alternates represent. 

Section 4. Vacancies in the membership of the Code Authority for 
unexpired terms shall be filled by selection by the surviving repre- 
sentatives of the group in which the vacancy has occured. 

Section 5. The Administrator shall have the power to remove Industry 
Members of the Code Authority for cause, and to fill any vacancy 
resulting from the exercise of such power, pending the selection 
of new members. 

Section 6. The Administrator shall be the judge of the qualifications 
and term of office of the Administration M e mber and shall have the 
power of appointment of such member. 

Section 7. In accordance with Office Order Ho. 81, it is provided 
as follows: 



9811 



-539- 



1. The Administrator will appoint a labor 
adviser and a consumer adviser to the Administra- 
tion Member (or Members) of each Code Authority. 
The labor and Consumer Advisory Boards will immedi- 
ately submit to the Administrator lists of nominees 
qualified for these positions. 

2. The Administration Member will arrange with the 
Code Authority that these advisers have access to 

the minutes of all Code Authority meetings and 
of the meetings of all Code Authority agencies or 
sub-committees. The Advisers are not members of 
the Code Authority, and will attend meetings only 
upon request of the Administration member or of 
the Code Authority. They have, however, the right 
to appear before the Code Authority to make state- 
ments on specific subjects. 

3. The advisers will keep all information con- 
cerning the industries to which they are asigned, 
gained by virtue of their position, strictly con- 
fidential. They mill confine their reports, advice, 
recommendations, and other statements regarding 

'• these industries to the Administration Member of 
the Code Authority, the Divisional Administrator, 
and the appropriate Advisory Board.' 

ARTICLB V 
Officers and Committees 

Section 1. The Code Authority shall choose a Chairman who shall 
preside at meetings and exercise such other functions as may be 
delegated to him by the Code Authority. 

Section 2. The Code Authority shall choose a Vice-Chairman who 
shall preside at any meeting at which the Chairman is absent or 
is disqualified for any reason, and shall possess the same autho- 
rity at this meeting that the Chairman possesses. 

Section 3. The Code Authority shall choose a Secretary who shall 
keep all records and minutes of the Code Authority and all other 
matters of which a record shall be ordered by the Code Authority. 
He shall issue notices for all meetings. 

Section 4. The Code Authority shall choose a Treasurer who shall 
safeguard and account for the funds of the Code Authority, keep 
accurate and full records of receipts and disbursements, render to 
the Code Authority an accounting of all transactions and perform 
such other duties as may be assigned by the Code Authority. 

Section 5. The duties of any officer may in whole or in part be 



9811 



-54-0- 



assigned under authority of the Code Authority to an agent or 

agency. 

Section 6. The Code Authority may choose such confidential 
agents or agencies, as it deems necessary, in order to carry out 
any of the functions, powers and duties vested in it by the Code 
and shall arrange the compensation for these confidential agents 
or agencies. 

Section 7. All records and minutes of the Code Authority shall 
at all tiroes "be at the disposal of the Administrator. The Indus- 
trial, Labor and Consumers Advisory Boards of the IIPA shall upon 
approval of the Administrator, have access to such records, and 
shall have the ri fe ht, upon reasonable notice, to appear before the 
Code Authority in session or to submit to it, any criticisms, 
complaints or suggestions; and in pxirsuance thereof, may appeal 
to the Administrator. 

Section' 8. The Code Authority may appoint and provide for the 
expense of some of all of the following standing committees and 
such other committees as it may from time to time be necessary 
for carrying out its functions, which committees shall operate 
under the direction of the Code Authority: 

a) Finance, Budget and Label 

b) 'j.-> define semi-skilled worker 

c) To provide regulations regarding handicapped 
persons 

d) To provide regulations for the safety and health 
of enrol oyees 

e) To study the question of homework 

f) To draw up a written agreement for contractors . 
c) To draw up a constitution and by-laws 

h) To take care of coordination with other codes 
i) To develop industrial planning and fair trade 

practices 
j) To establish a xiniform cost system 
k) To draw up regulations regarding style piracy 
l) To establish a system for the issuance and sale 

of labels 
m) To establish regulations to govern sales below 

cost 
n) To collect statistics and reports 

Section 9. The Code Authority shall have the power to remove from 
office any member or members of any subordinate agency created 'by 
the Code Authority if sucn member or members were appointed to it. 
It shall also have the power to modify the functions of, or to 
terminate the use of, any such agency if in its judgment such action 
is necessary for the prober administration of the Code. 



3811 



-541- 



AHUICE3 VI 

Section 1. The principal office of the Code Authority shall 
be located in the City of Hew York. The Code Authority may also 
establish and maintain branch offices wherever it deems nec- 
essary. 

Section 2. The Code Authority shall meet on the second Thursday 
of each month at its principal office unless otherwise designated 
oy the Code Authority. 

Section 3. Special meetings of the Code Authority may be called 
by the Chairman or by the Chairman upon the written request of 
the Administrator, his representatives, and Administration Member, 
or two Industry Members of the Code Authority. 

Secti:n 4. A majority of the industry members (regular represen- 
tatives or alternates directed to act as regular representatives) 
of the Code Authority shall constitute a quorum for the trans- 
action of business. No determination of the Code Authority shall 
be made without the affirmative vote of a majority in numbers of 
the Code Authority. If a quorum be present at any given meeting 
and a majority of such quorum s1tp.11 affirmatively approve a given 
matter, the same shall become effective when and if there slis.ll be 
received and filed in writing in the office of the Code Authority 
assents thereto which added to the number voting in person shall 
constitute a majority of the industry members of the Code Autho- 
rity. 

Section 5. The Code Authority, all subordinate agencies, and all 
Industrial Adjustment Agencies crested "o-j the Code Authority, shall 
keep a complete record of proceedings at all meetings, and certified 
copies of minutes and other records and data shall be filed as a 
permanent record, at the business office of the Code Authority and 
with the Administrator of the 1 T . 3. A. 

Section 6. Permanent records of the Code Authority filed with the 
H. ?.. A. shall be available to the Advisory Boards of the IT. R. A. 
subject to the approval of the Administrator. Publication of informa- 
tion thus secured shall not be made except with consent of the Code 
Authority. 

ARTICLE VII 

The Code Authority shall establish Industrial Adjustment 
Agencies for the purpose of handling trade practice dis- 
putes and labor disputes. 

Section 1. The Code Authority shall appoint a trade Practice Com- 
plaints Committee of three members. The Administration member shall 
be a member of this committee without vote, but with a veto power 
subject to review by the; Administrator. An executive secretary and 
legal counsel shall also be appointed as either members of the com- 
mittee or as employees, 

3811 



-542- 



This committee shall handle trade practice complaints and disputes 
in the first instance, and adjust them in accordance with the affected 
provisions of the Code, and in accordance with the provisions of the 
National Industrial Recovery Act. 

The functions and powers of this committee may in whole or in part 
be delegated, under authority of the Code Authority, to confidential 
agents or agencies. 

Section 2. The Code Authority, in accordance with Administrative 
Order Ho. X-12, dated March 30, 1954, shall appoint an. Industrial 
Relations Committee of six members, consisting of three industry 
members and three labor members. 

The Administration member shall be a member of this committee, with- 
out vote but with a veto power subject to review by the Administrator. 
An executive secretary and legal counsel shall also be appointed as 
either members of the committee or as employees. 

This committee shall handle labor complaints and labor disputes in 
the first instance and adjust them in accordance with the affected 
provisions of the Code and in accordance with the provisions of the 
National Recovery Act. The functions and powers of this Committee 
may in whole or in part be delegated under authority of the Code 
Authority to confidential agents or agencies. 

Section 3. The committee to develop industrial planning and fair 
trade practices, which shall meet with the trade practice committee 
appointed under such other codes as may be related to the industry, 
for the purpose of formulating fair trade practices to govern the 
relationships between production and distribution employers under 
this Code and under such others, to the end that such fair trade 
practices may be proposed to the Administrator as amendments to this 
Code and such other codes. 

Section 4. Pursuant to Article VI, Section 8 (d) of the Code, the 
Code Authority may use such trade associations and other agencies 
as it deems proper for the carrying out of any of its activities 
provided for herein and to pay such trade associations and agencies 
the cost thereof, provided that nothing herein shall relieve the 
Code Authority of its duties and responsibilities under this Code 
and that such trade associations and agencies shall at all times be 
subject to and comply with the -orovisions hereof. 



■ ARTICLE VIII 

Section 1. The Code Authority may include in its expense accounts 
all necessary and proper costs of code administration. 

Section 2. The expense of administering this Code shall be assessed 
by the Code Authority against all members of the industry, subject to 
such rules and regulations as the Administrator may approve. 

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Sectim 3. The Code Authority shall prepare a detailed "budget 
upon which the assessment shall be based. Pursuant to the Code, 
the budget and plan of assessment must be approved by the Adminis- 
trator. This budget and plan of assessment shall be available to 
all members of the industry and such members, as desire, shall be 
given an opportunity to b e heard on the method -and amount of assess- 
ment . 

Section 4. Pursuant to Article Vii of the Code, and subject to the 
approval of the Administrator, the Code Authority shall have the 
exclusive right of this industry to issue and sell labels to the 
members thereof. The Code Authority shall establish rules and regula- 
tions and appropriate machinery for the issuance and sale of labels 
and the inspection, examination and supervision of the practices of 
members of the industry, xising such labels for the purposes of ascer- 
taining the right of such members of the industry to the continued 
use of said labels; or protecting purchasers in relying on said 
labels; and of insuring to each individual member of the industry 
that the symbolism of said label will be maintained by virtue of 
compliance with the provisions of this Code by other members of the 
industry using said labels. 



AHTICL3 IX 

Section 1. The Code Authority shall designate a disinterested 
statistical agency (this may be a Government Bureau) which shall 
collect information and statistics from members of the Industry 
for the compilation of reports as to wages, hours of labor, number 
of workers, types of workers, production, type of merchandise pro- 
duced, volume of sales, methods of sales, and any other pertinent 
matters, in accordance with the provisions of the Code and deemed 
necessary by the Code Authority and the directions of the Administra- 
tor thereunder. In addition such statistical information as the Ad- 
ministrator may deem necessary for the purpose recited in Section 3 
(a) of the Act, shall be furnished to such Federal and State agencies 
as the Administrator may designate. 

Section 2. Such statistics and information, except as otherwise may 
be provided by this Article, shall be kept confidential. ITo publica- 
tion thereof in any manner shall be made to anyone, other than in 
summary form and without individual identification; provided, however, 
trat any of such statistics and information shall be made avftlfc-ble to 
the Administrator. Any member of the Code Authority or officer or agent 
thereof who discloses such information in violation of this section may 
be removed from off ice. by the Administrator, either on his own initiative 
or upon complaint me.de by any party affected by such disclosure. 



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ARTICLE X 
INTERPRETATIONS, EXCEPTIONS, EXEMPTIONS, MODIFICATIONS 
AND AMENDMENTS OF CODS. 

Section 1. Definition of "Interpretations" This term includes 

all rulings on the moaning of the language of a code where the 
intent of that language is in doubt; i.e., where a knowledge of 
the surrounding circumstances and of the general policies of 
IT. 3. A. on the part of the person making the rulings, fails to 
remove the necessity for a decision on which reasonable men, 
equally well informed, might differ. Where no decision is re- 
quired on which reasonable men, equally well informed, might 
differ, the ruling is not an interpretation but merely an explana- 
tion. 

Section 2. Definition of "Exceptions" and "Exemptions" These 

terms include all rulings whereby an individual, group, or class 
is released from the full operation of a prevision of a code. 

Section 3. Definition of "Modifications" This term includes all 

rulings whereby a code is amended by adding a provision thereto or 
changing or omitting any provision thereof. 

Section ■!. Provisional Interpretations '.Then the immediate course 

of action of the iDerson seeking an interpretation may depend on the 
answer given, the Code Authority shall give a provisional ruling on 
the interpretation requested. At the same time, it shall be made 
clear that the ruling so given is subject to review by the II. R. A. 
This provisional ruling shall not be circularized throughout the 
Industry, but shall be given solely for guidance of the particular 
person or persons involved, including any interested party or group 
who would be affected by not being immediately informed of the 
provisional ruling. The transcript of such a provisional interpre- 
tation shall be sent to the IT. It. A., which will notify the Code 
Authority regarding the approval, disapproval, or modification of the 
interpretation as given. 

Section 5. Requests for Immediate Interpretations 'where the final 

ruling on an interpretation must be made immediately, and a provision- 
al ruling by the Code Authority is not sufficient, the Code Authority 
shall communicate with the IT. 3. A. and request an immediate ruling 
on the interpretation. 

Section 6. Final rulings ITo final rulings on matters covered by 

Sections 1, 2 and 3, of this Article may be made except by the Adminis- 
trator, after such notice and hearing as he may require. The Code 
Authority shall give the widest publicity to final rulings. 

Section 7. Procedure on Exceptions and Exemptions In any case in 

which a member of the Industry believes that the operation of the 
Code imposes undue hardship, or is not carrying out the purpose of 
the Act, such member may set forth such facts in a petition to the 
Code Authority requesting an exception or exemption from a specific 



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provision of the Cod 3. The Code Authority, within thirty days 
after such petition is filed, shall submit it, together with its 
findings and recommendations to the Administrator. If the Code 
Authority fails to make findings and recommendations within such 
period, or if it recommends dismissal of the petition, such member 
of the Industry may petition the Administrator for an exception 
or exemption. 

Section 8. Procedure on Amendments and Modifications All 

proposals for amendments to or modifications of the Code by 
members of the Industry, shall be submitted in the- first instance 
to the Code Authority for its recommendation. The Code Authority 
shall immediately consider such proposals and shall recommend to 
the Administrator approval, modification, or disapproval thereof. 

Section 9. Consultation with Administration Member- — The Industry 
Members shall consult with the Administration Member of the Code 
Authority and his Advisers in connection with the- preparation of- 
findings and recommendations for interpretations, exceptions, 
exemptions, modifications, and amendments to the Code. 

ARTICLE XI 

ARBITRATION"- 

Section 1. Procedure Governing Arbitration Vlith the approval of 

the Administrator, the Code Authority may establish procedure for 
the arbitration of specific tyoes of trade practice and labor 
controversies arising under the Code. Such procedure should 
accord with State and Federal laws. 

ARTICLE XII 

CODE AUTHORITY REGULATIONS 

Section 1. Regulation of Procedure In addition to the By-laws 

the Code Authority may adopt Regulations to govern its procedure 
in the exercise of powers granted to it under the Code, and the 
limits of which are defined in the Code and By-laws. Such Regu- 
tions shall outline detailed procedures, the fundamentals of which 
have been embodied in the By-laws. They shall be subject to the 
disapproval of the Administrator. 

Section 2. Identification of Code Authority Regulations All 

Code Authority Regulations and all : .•amendments thereto, issued in 
accordance with Section 1 above, shall be clearly described as 
"Regulations of the Code Authority of the Ladies' Handbag Industry", 
and shall be identified in such manner that every general subject 
shall be designated by article number, and every specific provision 
of each article be section number. 

Section 3. Amendments to Regulations Code Authority Regulations 

may be amended in accordance with procedure similar to that required 



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for the initial issuance of such regulations. 

ARTICLE XIII 

POWERS AND LIABILITIES 07 CODE AUTHORITY 

Section 1. Non-liability of Code Authority Members — Nothing contained 

in these By-laws shall constitute the members of the Code Authority 

partners for?.ny purpose. Nor shall any member of the Code Authority 

be liable in any manner to anyone for any act of any other member, 

officer, agent, or employee of the Code Authority. Nor shall any 

member of the Code Authority, exercising reasonable diligence in the 

conduct of his duties hereunder, be liable to anyone for any action 

or omission to act under these By-laws, or under regulations adopted 

pursuant to Article XII of these By-laws, except for his own wilful 

misfeasance or nonfeasance. Nothing herein shall relieve any member 

of the Code Authority from duties or responsibilities imposed upon 

him by the Code. , . 

> 

ARTICLE XIV 

EFFECTIVE DATE AND AM3NDMMTS 0? BY-IAWS 

Section 1. Effective Date These By-laws shall become effective 

when approved by the Administrator. 

Section 2. Amendments to 3y-Laws Amendments to these By-laws may 

be adopted by a 2/3 (two thirds) vote of the Code Authority, and 
shall become effective when. approved by the Administrator. 

ARTICLE XV 

GENERAL PROVISIONS 

Section 1. Subordination of By-laws to Code and Act No provision 

in these By-laws shall be so applied as to conflict with any provision 
of the Act of of the Code. 

Section 2. Availability of By-laws These By-laws and all Regulations 

and all amendments to such By-laws and Regulations shall be made avail- 
able to all members of the Industry. 



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9811 



EXHIBIT E-l 



Brief - National Hand Bag Salesmen's 
Association 



r548- 
EXHIBIT E-l 

BRIEF OF THE 
NATIONAL HANDBAG- & ACCESSORIES SALESMEN ' S ASSOCIATION 
Respectfully submitted "by 

BA1TJAMIN MILLER - COUNSEL 



The National Handbag & Accoessories Salesmen's Association repre- 
senting tiie salesmen in the handbag and accessories industry has among 
other objectives and purposes the improving and aiding a spirit of 
cooperation between employee and manufacturer, cooperation with the 
code authority and the NRA and further the promotion of peace and 
harmony in the industry in said relationship, thus resulting in putting 
the industry and those who derive their living from it back on a sounder 
and more profitable basis. 

Now, more than ever, are the manufacturers' problems the salesmen's 
problems insofar as it remains in the power of some 900 handbag salesmen, 
who travel the 48 states to patrol their territories and aid in en- 
forcing the handbag code. 

Prior to 1928, the handbag salesmen, collectively, were a highly 
respected group of men, upholding the dignity of their calling earning 
a substantial livelihood for themselves and th^ir families, and doing 
human service for their employers who reaped the financial reward. 
During the ore-depression days, it was unheard of for a handbag sales- 
man to represent more than one manufacturer. This condition was made 
possible, not so much because business conditions were good, but due to 
the fact that the rate of commissions was more munificent. In years 
prior to 1928, at least 95'^ of the handbag salesmen made money for 
themselves and their employers because their commissions ranged approxi- 
mately 10^ and upwards. However, since th