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in a given time, turn out about three times as much work as a German press, with the same number of laborers; also, quick delivery is the great obstacle in competition that the German can not overcome. The American buyer to-day likes to give his order one day and have his goods shipped the next day. He knows that it must be many weeks, if he sends his orders to Germany, before he can see his goods. These advantages, in favor of the American lithographer, are so great that even were it an infant industry it would need no protective duty. Respectfully submitted. V. C. WARD,

Agent for Emil Pinkau & Co., Leipzig.

Mr. V. C. WARD, New York.

EXHIBIT A.

COLUMBUS, OHо, December 11, 1908.

DEAR SIR: Thanks for your letter of 10th. Samples will likely get in to-morrow. I will consider them. But I have some fine American samples, which are satisfactory, and much better than the Chicago sample sent you, at a very much lower price than you quote. Will want 100,000 of our buildings.

Yours, truly,

THE M. C. LILLEY & Co., Per Jos. PALLEN.

EXHIBIT B.

COLUMBUS, OHIO, December 19, 1908.

Mr. V. C. WARD, New York, N. Y.

DEAR SIR: We are returning sample postals by this mail. We thank you for your quotations. We are making up our drawing and expect to place order elsewhere at a less price than you quote for equal work.

Yours, very truly,

THE M. C. LILLEY & Co.,
PALLEN.

THE DETROIT PUBLISHING CO. SUBMITS SUPPLEMENTAL STATEMENT RELATIVE TO PICTORIAL POST CARDS.

Hon. SERENO E. PAYNE,

DETROIT, December 23, 1908.

Chairman Ways and Means Committee, Washington, D. C.

SIR: In accordance with your suggestion, I respectfully submit this memorandum supplementing letter of December 2.

The purpose of this brief is to make clearer important points alluded to, but not fully stated.

To avoid repetition, I recapitulate the facts already stated, giving you the necessary references. They are:

(a) This trade did not exist when the present schedule was made, being developed in the last ten years in this country.

(b) It was developed at the expense of home manufacturers and only reached serious volume five or six years ago.

(c) When we had created a market sufficient to make it valuable, it was invaded by foreign makers who have reaped nearly all the benefits of the trade without incurring the costs of creation.

(d) In spite of prices which have constantly fallen for six years, the proportion of trade absorbed by the foreigner has constantly increased until now it exceeds four-fifths of the total, and the American maker is in danger of being driven out altogether.

(e) The present duty is negligible, and in many cases is from onethird to one-seventh that of other articles printed in the same medium having no greater relative value and even a lesser percentage of labor

cost.

The advantages the foreign manufacturer has are:

1. He pays wages not exceeding one-third the American rates, and more often less.

2. The cost of initial designs (which is apart from the manufacturing cost of the card itself) is one-fifth to one-quarter that of similar designs made here.

3. All his materials are lower.

4. Copyrights at considerable cost for maintenance are necessary in this country to prevent stealing of designs, which is an expense foreigners save because of different laws abroad.

5. The nature of the domestic trade and the fact that Americans have no foreign markets compel making very much smaller average editions in this country than abroad, thereby greatly increasing the cost per unit manufactured even if there were no other handicaps such as wages.

Details as to the above facts will be found in the statements ofMr. George R. Meyercord, November 21.

Campbell Art Company.

The Albertype Company.

San Francisco maker.

Detroit Publishing Company.

The Rose Company.

Forbes Lithograph Manufacturing Company.

The greatest difference in wages noted is conservatively stated and can be easily verified further if any doubt remains in the minds of your committee. Disregarding expense of initial designs, the percentage which labor and overhead cost bears to the total in this country is rarely under 50 per cent and on an average not under 75, and even runs as high as 95 per cent of the total on some work.

The foreign maker often appropriates our designs, and even where copyrights exist it is most difficult to get recourse.

See Exhibit A, which includes five German cards all by different publishers and all copied from photographs or designs produced and copyrighted by us at our expense and stolen by the makers.

On fancy cards, and even on views of travel, the cost of the initial design is a large factor and may even exceed the manufacturing cost. The very low rate at which designs are obtained abroad is not only due to the great difference in all wages pertaining to the graphic arts, but is still further increased by the large numbers of art students

abroad who support themselves at very low rates in order to obtain educational advantages.

Copyrights to protect designs have not been explained, but they are no small tax. It may be answered that the expense of registration is trivial, but that expense is very small compared with the cost of maintenance of a copyright which includes making sure that every copy issued has the proper imprint. The inspection and verification and other technicalities add a heavy burden. The foreign maker has his designs protected abroad by the law without registration and without notice" or "imprint'' requirements.

Enough stress has not been laid upon the enormous advantage the foreigner has by reason of his large average editions. When he only pays one-third our wages it is easy to see this advantage, but it becomes more obscure when we speak of size of editions. In the first place, the foreign maker has a very much larger market to draw from, because he may, and in fact does, manufacture for practically the whole world. We are limited to this country alone. On all designs, therefore, which have an international use he makes editions for all countries, aggregating the whole in one lot. Where different type is required, he merely alters it for that section of the edition. As this includes nearly all the "fancy cards," his advantage in that trade is overwhelming. To show the importance of edition we will take a type of card which can be manufactured (exclusive of the cost of the design) for $15 per thousand in 1,000 editions. The same card in 5,000 editions would probably cost $5 per thousand. The addition of the cost of the design still further increases the margin against the American maker.

Reference has been made to the fact that the domestic maker is being driven out of competitive business. To explain what we mean by this: Where a customer has his own subjects, it is clear that anyone may bid on the work, and the customer will take the lowest price. The foreign makers now have almost a monopoly of this business If the American maker gets out designs of special merit and then incurs the expense of copyright and maintenance of copyright, he can preserve the business on those designs to himself, and it becomes in a measure noncompetitive, but he does it at an almost prohibitive handicap of adverse costs and at the risk of finding that some foreign house will copy the designs, altering them enough to escape technical infringement if they prove salable.

COST OF IMPORTATION.

Cards made by engraving or photogravure of photo-gelatin work pay a 25 per cent ad valorem duty. Because of the lower duty upon lithographed cards, which is practically nil, all cards which can be forced into this process are now imported in that state.

Lithographed cards come under paragraph 400 as lithographic prints exceeding eight-thousandths of an inch and not exceeding twenty-thousandths of an inch in thickness and not exceeding 35 square inches cutting size. They pay 5 cents per pound, which (according to the weight of the card) equals from 35 to 55 cents per thousand cards. Transportation from the factories abroad to New York varies from 20 to 30 cents per thousand, so that the total cost of duty and transportation is from 55 to 80 cents per thousand cards.

This is irrespective of the value. If this same work exceeded 400 square inches it would pay 35 per cent duty. As they are generally made in large sheets containing from 30 to 70 cards and these sheets are subsequently cut up, it will be seen that if they were imported before the manufacture is completed they would pay much more duty than they do in the finished condition. To show the further absurdity, one card imported may cost ten times that of another and yet the duty remains the same for all. Playing cards, in which the average percentage of labor cost is lower, pay a specific duty of $1.92 per thousand plus a 20 per cent ad valorem, while the post cards pay rarely to exceed 50 cents per thousand specific duty alone.

WHAT THE NEW DUTY SHOULD BE

Your committee is asked by a number of interests to greatly increase the duties, and they indicate rates varying from 35 to 75 per cent ad valorem, and in other cases a specific duty, such as 35 cents per pound. All are agreed that cards should have a special class by themselves, irrespective of medium employed. We believe some specific duty is necessary, because this product is one peculiarly susceptible to even honest differences of opinion as to values, and also to intentional evasions on the part of makers. To illustrate: A foreign maker will print an edition of cards for England or Germany. In his first order he includes the cost of designs and plates. After delivery he figures the plates are on hand at no cost to himself. He then gives an American importer a subsequent edition or an excess from the first edition without any allowance for cost of designs or plate making, and the cards are valued accordingly for import purposes. This recourse is not open to the domestic maker, because costs are prohibitive so far as exporting is concerned. Consequently we are limited to the one market. While a specific duty is necessary, we do not believe it will be satisfactory alone. The reason is this: Cards are imported costing as high as $40 per thousand. It is evident that if the specific duty were fixed at $2.50 per thousand, what might be a satisfactory duty on a card costing $3 is no protection at all on a card costing $20. We strongly urge both a specific and an ad valorem duty, the same as now applied to decks of playing cards. They are imported under a specific duty of 10 cents per pack plus 20 per cent ad valorem (equivalent to $1.92 per thousand cards plus 20 per cent). The suggested specific rate of $2.50 per thousand on the post cards would be relatively a lower rate, and if there be added to that an ad valorem duty equal to the highest percentage rate applied to the processes employed in the article, we believe the result would not only be the most satisfactory in application, but the fairest that can be devised. It also permits fair importation.

It should be borne in mind that an initial specific duty providing some minimum is absolutely necessary in order to equalize the great difference in the average editions in this country and those abroad, and to equalize the great difference in cost of initial designs, and also to take care of the relative undervaluing, which is sure to occur in many cases by reason of designs and plates being already considered as paid for by previous editions. In fixing an ad valorem percentage, it should likewise be borne in mind that, in proportion to its value, the quality of work upon most pictorial cards is of a very high order, in

volving very high percentages in labor, and that its class of workmanship and relative expense per area is generally equal in the average to the highest class of work done in the process. That is why we say the ad valorem duty added should be the same as that of the highest class pertaining to the medium used. Again, it should also be borne in mind in considering the minimum that there is difficulty at times in determining the medium used in the manufacture. This is especially the case where more than one medium is employed on the same card. Of course, we are aware this difficulty is a strong argument in favor of a specific tax only, and we would favor it alone but for the wide range of price of the product which makes a combination duty imperative to give fair protection. To show your committee some of the different mediums employed we send you Exhibit B of cards covering seven different processes.

It may be asked why the domestic manufacturer is not driven out of the business with the excessive disadvantages under which he labors. The answer is that on competitive business he is practically driven out now, and only on special designs which he controls or work requiring a quicker delivery than can be gotten abroad is he able to maintain his place. This is the smaller market, and unless he is given a fair share of the larger market he will in time be forced out altogether.

QUALITY OF DOMESTIC WORK.

It is stated that purchases are made abroad because the quality of the domestic work is not sufficiently good. Such statements are false, for there is as good work produced in this country as any abroad.

DEFINITION OF PICTORIAL POST CARDS.

Pictorial post cards should be defined to include all cards of similar size and character, whether having the post card imprint or not. Frequently part of an edition is printed with the mailing imprint and part in blank, using the surplus for "place" or "tally cards" and other purposes. If the definition of the article is not made very inclusive, then importers will bring it in without the mailing imprint under different classifications if your committee decide to establish a separate class for all mailing cards regardless of the process by which they are made, as in the case of playing cards. All of which is respectfully submitted.

DETROIT PUBLISHING CO.,
W. A. LIVINGSTONE, Mgr.

THE ROSE CO., PHILADELPHIA, SUBMITS SUPPLEMENTAL BRIEF ASKING HIGHER DUTIES FOR LITHOGRAPHIC PRINTS.

PHILADELPHIA, PA., December 24, 1908.

COMMITTEE ON WAYS AND MEANS,

Washington, D. C.

GENTLEMEN: Following your request that I submit to you a schedule of classifications and desired rates of duty, with reasons for asking same, I beg to submit the following:

There should be no difference in duty between printed, lithographed, stamped, embossed, or engraved post cards, and there should be no

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