Approved Code No. 360 Registry No. 1609-1-02 

NATIONAL RECOVERY ADMINISTRATION 

CODE OF FAIR COMPETITION 

FOR THE 

BRUSH MANUFACTURING 

INDUSTRY 

AS APPROVED ON MARCH 23, 1934 

WE DO OUR PART 

\ 

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UNITED STATES 

GOVERNMENT PRINTING OFFICE 

WASHINGTON: 1934 

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Approved Code No. 360 

CODE OF FAIR COMPETITION 

FOR THE 

BRUSH MANUFACTURING INDUSTRY 

As Approved on March 23, 1934 

ORDER 

APPROVING ConE oF FAIR CoMPETITION FOR THE BRUSH MANUFAoTURING INDUSTRY 

An application having been duly made {ursuant to and in full 

compliance with the provisions of Title I o the National Industrial 

Recovery Act, approved June 16, 1933, for approval of a Code of 

Fair Competition for the Brush Manufacturing Industry, and hearings having been duly held thereon and the annexed report on said 

Code, containing findings with respect thereto, having been made 

and directed to the President : 

NOW, THEREFORE, on behalf of the President of the United 

States, I, Hugh S. J ohnsonz Administrator for Industrial Recovery, 

pursuant to authority vested in me by Executive Orders of the President, including Executive Order No. 6543-A, dated December 30, 

1933, and otherwise; do hereby incorporate by reference said annexed report and do find that said Code complies in all respects with 

the pertinent provisions and will promote the policy and purposes of 

said Title of said Act; and do hereby order that said Code of Fair 

Competition be and it is hereby approved, provided that Articles 

XIV and XV be eliminated from the Code. 

HUGH s. JOHNSON' 

Administrator for Industrial R ecovery. 

Approval recommended: 

GEo. L. BERRY, 

Division Administrator. 

wASHINGTON, D.C., 

March tE3, 1931,. 

483040-425-134-34 ( 423) 
REPORT TO THE PRESIDENT 

The PRESIDENT, 

The White House. 

Srn: A Public Hearing on the Code of Fair Competition for the 

Brush Manufacturing Industry, submitted by the American Brush 

Manufacturers Association, located at 505 Arch Street, Philadelphia, Penna., was conducted in Washington on the 21st of N ovember 1933, in accordance with the provisions of the National Industrial Recovery Act. The Association claims to represent 85 percent 

of the Industry. 

The maximum hours permitted un ler this Code are forty ( 40) per 

week, averaged over a three months period, with forty-eight hours 

permitted in any one week. Repairmen, engineers, electricians and 

cleaners are permitted to work an a\-erage of forty-four (44) hours 

per week during any three months period. Truckmen, watchmen 

and firemen are permitted to work forty-eight ( 48) hours per week. 

The minimum wage provided in this Code is thirty-two and a 

half cents (32:Y2 ¢) per hour. Females performing substantially the 

same work as males are to be paid the same rate of pay as male 

ell!p.loyees. Provision i made for adju tment of wages above the 

ll1llllmUm. 

The Brush :Manufacturing Industry includes establishments in 

which brushes and allied products are ma.nufactured, repaired and 

sold originally. Imports have caused a serious problem to this 

industry, those from Japanese an l German sources being the n1ost 

troublesome, having entered thi country in large quantities at 

extremely low unit prices. The making of brushes in Federal penitentiaries is another source of severe competition. The most modern 

of equipment is now being used by these institutions thus supplying 

the market with brushes which otherwise would be purchased from 

the industry. 

In 1929 approximately 7,200 people were employed in this industry. This had dropped to 5,400 in June, 1933. In October, 1933, it 

is estimated that this had risen to 6,600, an increase of 23.9 percent. 

This is only 8% under the peak year of 1929. 

Reports from members of the industry disclose that the minimum 

wage proposed in the Code will mean an increase over the minimum, 

just prior to the President's Re-Employment Agreement, of approximately 50 percent and an increase over 1929 of approximately 30 

percent. 

FINDINGS 

The Deputy Administrator in his final report to me on said Code 

having found as herein set forth and on the basis of all the proceedings in this matter; 

I find that: 

(a) Said Code· is well designed to promote the policies and purposes of Title I of the National Industrial Recovery Act, including 

(424) 
425 

removal of obstructions to the free flow of interstate and foreign 

commerce which tend to diminish the amount thereof and will provide for the general welfare by promoting the organization of industry for the purpose of cooperative action among the trade groups, by 

inducing and maintaining united action of labor and management 

under adequate governmental sanctions and supervision, by eliminating unfair competitive practices, by promoting the fullest possible 

utilization of the present productive capacity of industries, by avoiding undue restriction of production (except as may be temporarily 

required), by increasing the consumption of industrial and agricultural products through increasing purchasing power, by reducing 

and relieving unemployment, by improving standards of labor, and 

by otherwise rehabilitating industry. 

(b) Said Industry normally employs not more than 50,000 employees; and is not classified by me as a major industry. 

(c) The Code as approved complies in all respects with the pertinent provisions of said Title of said Act1 including without limitation Subsection (a) of Section 3, SubsectiOn (a) of Section 7, and 

Subsection (b) of Section 10 thereof; and that the applicant association is an industrial association truly representative of the aforesaid Industry; and that said association imposes no inequitable 

restrictions on admission to membership therein. 

(d) The Code is not designed to and will not permit monopolies or 

monopolistic practices. 

(e) The Code is not designed to and will not eliminate or oppress 

small enterprises and will not operate to discriminate against them. 

(f) Those engaged in other steps of the economic process have 

not been deprived of the right to be heard prior to approval of 

said Code. · 

This Industry has cooperated in a most satisfactory manner with 

the Administrator in the preparation of this Code. From evidence 

adduced during this hearing and from recommendations and reports 

of the various Advisory Boards it is believed that this Code as now 

proposed and revised represents an effective, practical, equitable solution for this Industry and for these rea..<:;ons this Code has been 

approved. 

Respectfully, 

MARCH 23, 1934. 

HUGH s. JOHNSON, 

Admini8trator. 
CODE OF FAIR COMPETITION FOR THE BRUSH MANUFACTURING INDUSTRY 

ARTICLE I-PURPOSES 

To effectuate the policies o£ Title I o£ theN ational Industrial Recovery Act, the following provisions are established as a Code o£ 

Fair Competition for the Brush Manufacturing Industry and shall 

be the ,standard of £air competition :for this Industry and binding 

upon every member thereof. 

ARTICLE II-DEFINITIONS 

1. The term " Industry " or " Brush Manufacturing Industry ", 

as used herein includes the manufacturing, repairing and original 

selling and distributing by manufacturers o£ brushes, and kindred 

and allied products twisted in wire, and such branches or subdivisions thereof a.s may from time to time be included under the provisions of this Code, by the President o£ the United States after 

uch notice and hearing as he may prescribe. 

2. The term ~'member of the Industry ' includes, but without 

limitation, any individual, partnership, association, corporation or 

other form of enterprise engaged in the indu try,. either as an employer or on his or its own behalf. 

3. The term" employee" as used herein includes any and all persons engaged in the industry, however compensated, except a 

member of the industry. 

4. The term" carrying account' as used herein means one where 

an understanding exists between the seller and the buyer to the effect 

that the buyer shall be required to pay his account with the seller 

down only to a ,specified amount, regardless of when the amount is 

due, resulting substantially in the effect of a consignment to that 

extent. 

5. The terms "Act " and "Administrator " as used herein mean 

respectively Title I of the National Industrial Recovery Act, and 

the Administrator £or Industrial Recovery. 

ARTICLE III-HoURs 

1. No employee, except as hereinafter provided, shall be permitted 

to work more than forty (40) hours per week, when averaged over 

any three months period~ nor more than forty-eight ( 48) hours in 

any one week, nor more than ten (10) hours in any one day. 

(a) The provi,sions of this article shall not apply to employees 

engaged in an executive, administrative, supervisory and/or technical capacity (excluding however persons engaged in skilled operations), who receive thirty-five dollars ($35.00) or more per week, 

nor to outside salesmen. 

(426) 
427 

(b) No repairman, engineer, electrician or cleaner, excluding machine cleaners, shall be permitted to work more than an average of 

forty-four (44) hours per week during any three (3) months period 

nor more than forty-eight (48) hours in any one week. 

(c) No truckdriver, watchman and/ or fireman shall be permitted 

to work more than forty-eight ( 48) hours during any one week. 

(d) The provisions of this article shall not apply to employees 

engaged in emergency repair work, involving the protection of life 

or property or repairs to machinery in the case of a breakdown or 

to permit the continued normal operation of such machinery, provided, however, that all such employees shall be paid at the rate of 

time and one-half their normal rate of compensation :for all hours 

worked per week in excess of :forty-four ( 44) hours per week. 

2. No employee shall be permitted to work for a total number of 

hours in excess of the number of hours prescribed herein, whether he 

be employed by one or more employers. 

ARTICLE IV-WAGES 

1. No emrloyee shall be paid at a rate less than thirty-two and a 

half cents ( 32lf2¢) per hour. 

2. This Article establishes a 1ninimum rate of pay which shall 

apply, irrespective of whether an employee is actually compensated 

on a time-rate, piece-work performance or other basis. 

3. Female employees performing substantially the same work as 

male employees shall receive the same rate of pay as male employees. 

4. It is the policy of the members of this Industry to refrain from 

reducing the compensation for employment which compensation was 

prior to June 16, 1933, in excess of the minimum wage herein set 

forth; notwithstanding, that the hours of work in such employment 

may be reduced; and, unless since such date such adjustments have 

been made, all members of this industry shall endeavor to increase 

the pay of all employees in excess of the minimum wage, as herein 

set forth, by an equitable adjustment of all pay schedules. 

~1\RTICLE V-GENERAL LABOR PROVI SIONS 

1. No person under sixteen ( 16) years of age shall be employed 

in this industry; nor any one under eighteen (18) years of age at 

operations or occupations which are hazardous in nature. The Code 

Authority shall submit to the Administrator within sixty (60) days 

after the effective date of this Code, a list of such operations or 

occupations. In any state an employer shall be deemed to have complied with this provision as to age if he shall have on file a certificate 

or permit duly issued by the authority in such State empowered to 

issue employment or age certificates or permits, showing that the 

employee is of the required age. 

2. In compliance with Section 7 (a) of the Act it is provided: 

(a) That employees shall have the right to organize and bargain 

collectively through representatives of their own choosing, and shall 

be free from the interference, restraint or coercion of employers of 

labor, or thejr agents, in the designation of such representatives or 

in self-organization or in other concerted activities for the purpose 

of collective bargainjng or other mutual aid or protection. 
428 

(b) 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 

(c) That, empioyers shall comply with the maximum hours of 

labor, minimum rates of pay and other conditions of employment 

approved or prescribed by the President. 

3. No employer shall reclassify employees or duties of occupations 

performed as they existed on October 1, 1933, or engage in any other 

subterfuge, for the purpose of defeating the purpose of the Act or of 

thi Code. 

4. No provision in this Code shall supersede any State or Federal 

Law which imposes on employers more stringent requirements as 

to age of em.ployees, wages, hours of work, or as to safety, health, 

sanitary or general working conditions, than are imposed by this 

Code. 

5. All employers shall post and keep posted complete copies of 

Articles III, IV, V and VI of this Code relating to hours, wages and 

labor in c·onspicuous places accessible to employees. 

6. Every employer shall make reasonable provision for the safety 

and health of his employees at the place and during the hours of 

their employment. 

ARTICLE VI-HOME wORK 

1. All home work in this Industry is hereby prohibited, except 

by specific permission of the Administrator in each individual case, 

and provided employees engaged in home work shall be paid the 

same wage rates that are paid for identical occupations in the shop. 

ARTICLE VII-DIVISIONAL 0RGANIZA TION 

1. The Brush :Manufacturing Industry shall be divided into the 

following divisions: 

l

a) Toilet Brush Manufacturers' Division. 

b) Shaving Brush Manufacturers' Division. 

c) Paint and Varnish Brush Manufacturers' Division. 

(d) Household Brush Manufacturers' Division . 

. (e) Industrial, Jewelers' and Dental Brush Manufacturers' DivisiOn. 

(f) Twisted-in-vVire Manufacturers' Division. 

(g) Wire Brush Manufacturers' Division. 

2. Additional Divisions may from time to time be formed within 

the Industry with the approval of the Administrator. 

ARTICLE VIII-ADMINISTRATION 

ORGANIZATION AND CONSTITUTION 

1. A Code Authority is hereby established to cooperate with the 

Administrator in the administration of this code and shall consist 

of twenty-one (21) members, or such other number as may be approved from time to time by the Administrator, to be selected as 
429 

hereinafter set forth. The Administrator in his discretion may 

appoint not more than three (3) additional members without vote 

and without cmnpensation from the industry, to serve for such period 

of time and to represent the Administrator or such group or groups 

as he may designate. 

(a) The Code Authority shall consist of three (3) representatives 

of each of the above named eli visions who shall be elected by each 

division through a fair method of election approved by the Administrator. Any member of the Industry within that particular 

division is eligible to vote at meetings of the division for the election of members representing the division upon the Code Authority. 

Under no circumstance shall the Code Authority be composed of 

persons more than one of whom is an officer, director, employee 

or agent of the same company or any subsidiary company. 

2. Each trade or industrial association directly or indirectly participating in the selection or activities of the Code Authority shall 

impose no inequitable restrictions on its membership, and shall submit to the Administrator true copies of its articles of association, 

by-laws, regulations, and any amendments when made thereto, together with such other information as to membership, organization 

and activities as the Administrator may deem necessary to effectuate the purposes of the Act. · 

3. In order that the Code Authority shall at all times be truly 

representative of the Industry and in other respects comply with 

the provisions of the Act, the Admini trator may prescribe such 

hearings as he may deem proper; and thereafter if he shall find 

that the Code Authority is not truly representative or does not in 

other respects comply with the purpose of the Act, he may require 

an appropriate modification in the method of election of the Code 

Authority. 

4. Any member 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 sus- taining his reasonable share of the expenses of its administration. 

Such reasonable share of the expenses of the administration shall 

be determined by the Code Authority subject to the disapproval 

of the Administrator, on the basis of volume of business and/or 

such other factors as may be deemed equitable. 

5. Nothing contained in this Code shall constitute the members 

of the Code Authority partners for any 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 

this Code except for his own willful mis-feasance or non-feasance. 

6. If the Administrator shall determine that any action of a code 

authority or any agency thereof may be unfair or unjust or contrary 

to the public interest, the Administrator may require that such 

action be suspended to afford an opportunity for investigation of the 

merits of such action and further consideration by such code author-
430 

ity or agency pending final action, shall not be effective unless the 

Administrator approves or unless he shall fail to disapprove after 

thirty (30) days' notice to him of intention to proceed with such 

action in its original or modified form. 

7. The Code Authority shall have the following further powers 

and duties: 

(a) To administer the provisions of this Code, provide for the 

compliance of the industry with its provisions and to propose and 

submit to the Administrator its recommendations for amendments 

and/ or modifications of this Code which shall become effective as a 

part hereof upon approval of the Administrator after such notice 

and hearing as he shall specify. 

(b) To adopt by-laws and rules and regulations for its procedure 

and for the administration and enforcement of the Code. 

(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 to such administrative andjor government agencies as the Administrator may designate, which administrative and/or government agencies shall hold the same confidential 

except as may be directed by the Administrator or as may be required by law. Nothing in this Code shall relieve any member of 

the industry of any existing obligations to furnish reports to any 

government agency. No individual reports shall be disclosed to any 

other member of the Industry or any other party except to such 

governmental agencies as may be directed by the Administrator. 

(d) To use such trade associations and other agencies as it deems 

proper for the carrying out of any of its activities provided for 

herein, provided that nothing contained herein shall relieve the 

Code Authority of its duties or responsibilities under this Code and 

that such trade associations and agencies shall at all times be subject to and comply with the provisions hereof. 

(e) To secure from members of the Industry who assent to this 

code and/or participate in the activities of the Code Authority such 

proportionate payment of the reasonable expenses of maintaining 

the Code Authority as may be determined by the Code Authority 

to be fair and equitable. 

(f) To recommend to the Administrator further trade practice 

provisions to govern members of the several Divisions in their relations with each other or with other industries and to recommend 

to the Administrator measures for industrial planning, including 

stabilization of employment. 

ARTICLE IX-SALES PROVISIONS 

1. Each division of the Industry may, by an affirmative vote of 

sixty percent ( 60%) in number and dollar volume of the manufacturers of such division, recommend an adequate system for cost finding, capable of uniform application within such division, and which 

members of such division shall adopt or conform their accounting 

systems to, within fifteen (15) days after its approval by the Admin-
431 

istrator. Said system for cost finding shall be used by all members 

of the division as a basis for cost finding of all products of the division, and within such division no member shall sell such products 

below his individual cost as determined by the use of such cost 

finding system, except as hereafter provided. 

(a) Any manufa-cturer of the Division may dispose of products 

which are known as '~seconds", "close-out numbers", "sample 

stocks" and "sample line brushes" below cost if he first submits 

to an impartial agency approved by the Code Authority by registered mail a descriptive list of such products together with quantities 

and prices at which they will be offered, and the prices so named 

shall not be reduced unless and until the manufacturer files reviseJ 

selling prices with such im.partial agency, and thereafter, upon the 

sale of such products the 1nanufacturer shall immediately notify 

such impartial agency advising the name and address of the buyer. 

In no case shall the sale of such products exceed such percent of the 

total volume of dollar sales of such manufacturer in one year, as may 

be determined by each Division from time to time, subject to the 

ap~roval of the Administrator. 

(b) Any manufacturer of the Division in order to meet bona fide 

competition in any specific instance may sell the products of such 

Division a.t a price not less than the lowest competing price of comparable items. · 

2. When a cost finding system shall have been adopted as prescribed above by any Division and the Code Authority finds that a 

manufacturer is selling the products of such Division in violation of 

this Article, it may require such manufacturer to submit to an impartial agency approved by the Code Authority relevant and complete data regarding such sales including all elements of cost properly and accurately figured, and if the Code Authority finds that such 

sales constitute a violation of this Code it may submit the same to the 

Administrator for appropriate action. 

3. Any division of the Industry may elect through an affirm.ative 

vote of sixty percent (60%) in number and sixty percent (60% ) in 

dollar volume to sell its products only upon open prices, terms and 

conditions filed by each member of such division, with such impartial 

agency as the division, with the approval of the Administrator, may 

determine. Each member of such division shall then immediately 

file with said agency his current price list and discount sheet at which 

he proposes to sell the products of such division and any changes in 

prices by any member of such division shall be filed with said agency 

and shall become effective immediately upon the filing thereof, or 

sixty ( 60) days after the effective date of this Code they shall become 

effective after such period or time as shall hereafter be established 

by the Code Authority with the approval of the Administrator. 

Such agency shall immediately notify all other members of the division of such changes and shall also make the same available to any 

other interested party who may apply for same. Variations from 

such open and publicly announced prices, terms and conditions, shall 

constitute an unfair method of competition. 
432 

ARTICLE X-TRADE PRACTICES 

The following practices shall constitute unfair methods of competition and are prohibited: 

1. No member of the industry shall falsely mark or brand any 

product of the industry which has the tendency to mislead or deceive 

customers or prospective customers, whether as to the grade, quality, 

quantity, substance, character1 nature, origin, size, finish or preparation of any product of the Industry. 

2. No member of the Industry shall publish or cause to be published advertising (whether printed, radio, display or of any other 

nature) which is misleading or inaccurate in any 1naterial particular nor shall any member in an way misrepresent any product of the 

industry. 

3. 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 such member interfere with or 

obstruct the performance of such contractual duties or services. 

4. No member of the industry shall extend to certain purchasers 

any rebates, refunds, commissions, credits, special services, privileges or discounts not extended to all purchasers of the same class 

on like terms and conditions. 

(a) Nor give allowances for advertising or extra discounts, or 

datings on billshor special credit terms, which are not extended to all 

purchasers of t e same class under like terms and conditions. 

(b) Nor make allowances and/or payments, directly or indirectly, 

to or for a customer in connection with that customer's cooperative 

advertising, which are not extended to all purchasers of the same 

class under like terms and conditions. 

(c) Nor make allowances andjor payments, directly or indirectly, 

for space within and/or on a buyer's premises for any purpose whatsoever, which are not extended to all purchasers of the same class 

under like terms and conditions. 

5. No member of the industry shall issue invoices, or other documents covering the sale of brushes in which the prices, terms, discounts, allowances, or any other condition or terms of sale or facts 

relating thereto are falsely stated; or issue invoices or other documents with the understanding that the buyer is to pay a price or 

receive any considerations that are different from those shown on 

the invoice. 

6. No member of industry shall knowingly ship or deliver brushes 

which do not conform to samples submitted, or to specifications upon 

which prices are quoted or to other representations made prior to 

securing an order. 

7. No member of the industry shall knowingly use or substitute 

materials inferior in quality or of a different nature and character 

than those specified by the purchaser and promised at the time the 

order is accepted. 

8. No member of the industry shall either directly or indirectly 

exchange, promote, encourage or in any way assist in the exchange 

of brushes, other than those manufactured by him or bought for the 

purpose of resale. 
433 

9. No member of the industry shall ship or deliver any goods on 

consignment or engage in the practice of carrying accounts, as 

defined in Section 4 of Article II, whether in whole or in part, 

except that a manufachirer may take over a stock of goods on a 

consigned basis for legitimate credit reasons but in such case he 

shall immediately report the circumstances to the Code Authority 

and such stock of goods, so taken over, shall not be carried on 

consignment for a period longer than three months. 

ARTICLE XI-FREIGHT CHARGES 

1. No member of the Industry shall allow or pay, directly or 

indirectly, secretly or otherwise, freight and/or delivery charges 

except as follows : 

(a) It shall be optional with each member of the Industry to 

allow and/or pay freight andjor delivery charges but such allowances shall be not greater than f.o.b. manufacturer's shipping point 

with actual freight as defined by Interstate Commerce Commission 

classifications, allowed or prepaid to any point within the United 

States, and in no case shall store door delivery be prohibited. 

(b) In Zone 1, as defined under the Federal post office parcel 

post regulations surrounding the manufacturer's plant, uch manufacturer may make delivery by any means at his command. 

(c) If a manufacturer elects to allow or pay freight and/ or 

delivery charges outside of Zone 1, as defined by Federal post office 

parcel post regulations, he may elect to ship by any means at his· 

command provided the total allowances do not exceed the freight as 

described in Subsection (a) of this section. 

ARTICLE XII-MomFIOA TION 

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 Title I of the Act, from 

time to time to cancel or modify any order, approval license, rule 

or regulation issued under said Act. 

2. This Code, except as to provisions required by the Act, may be 

modified or amended on the basis of experience or changes in circumstances, such modifications or amendments to be based upon 

application to the Administrator and such notice and hearing as he 

shall specify, and to become effective on approval of the President 

unless otherwise provided. 

ARTICLE XIII-MONOPOLIES 

1. No prov1s1on of this Code shall be so applied as to permit 

monopolies or monopolistic practices, or to eliminate, oppress or 

discriminate against small enterprises. 

ARTICLE XIV-NoN-WAIVER OF CoNSTITUTIONAL RIGHTS 

1. By presenting this Code, those assenting thereto are not thereby 

waiving any of their constitutional rights.1 

1 Deleted as per paragraph 2 of order approving this Code. 
434 

ARTICLE XV-RIGHT TO OBJECT 

1. By presenting this Code, the members of the Industry do not 

hereby consent to any modification thereof and they reserve the 

right to object individually or jointly to any such modifications.1 

ARTICLE XVI-EFFECTIVE DATE 

1. This Code shall become effective on the second Monday after 

its approval by the President. 

Approved Code No. 360 

Registry No. 1609-1-02 

1 Deleted as per paragraph 2 of order approving this Code. 

0 

UNIV ERSITY OF FLORIDA 

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