Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: MILLER & LAMB, HARRY M. MILLER, AND JOHN W. LAMB 

DOCKET NUMBER: STIPULATION 10 

DATE: MAY 25, 1949 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES OF AMERICA 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Miller & Lamb, Harry M. Miller, and John W. Lamb 

Stipulation of Compliance Under the Commodity Exchange Act No. 10 

WHEREAS, the Secretary of Agriculture has reason to believe that Miller & 

Lamb, a partnership, and Harry M. Miller and John W. Lamb, individual members of 

such partnership, have violated Section 4b (D) of the Commodity Exchange Act by 

virtue of certain transactions involving the purchase and sale of commodities 

for future delivery for the account of customers of the said Miller & Lamb, and 

WHEREAS, no complaint with respect to such violations has been issued, and 

WHEREAS, the said Miller & Lamb, Harry M. Miller and John W. Lamb desire to 

enter into a stipulation pursuant to the provisions of Section 0.4 (a) of the 

Rules of practice under the Commodity Exchange Act, 

NOW, THEREFORE, the said Miller & Lamb, Harry M. Miller, and John W. Lamb, 

admit that the following facts are true, 

1. Miller & Lamb was at all times hereinafter mentioned and is now a 

partnership composed of Harry M. Miller and John W. Lamb, doing business at 171 

W. Quincy Street, Chicago, Illinois, with clearing house and membership trading 

privileges on the Chicago Open Board of Trade, hereinafter called the Open 

Board, a duly designated contract market under the Commodity Exchange 

Act. The said partnership was at all such times and is now a registered futures 

commission merchant under the Commodity Exchange Act. 

2. John W. Lamb was at all times hereinafter mentioned a member of the 

clearing house of the Open Board. The said John W. Lamb used such membership 

solely for the purpose of clearing trades made for his individual account. 

3. At all times hereinafter mentioned, Lewis E. Strauss, a member of the Open 

Board, was employed by Killer & Lamb as a broker to execute orders on the Open 

Board for customers of Miller & Lamb. 

4. On March 31, 1949, the said John W. Lamb had in his possession various 

orders to purchase and various orders to sell commodities for future delivery 

for customers of the said Miller & Lamb, as follows; 

Customer Quantity Commodity 

To Buy To Sell 

David Kerman 2 May Soybeans 

E. M. Hart 1 May Soybeans 

Alexander Wassermann 2 July Soybeans 

Ira W. Place 2 May Corn 

Fred C. Pratley 1 July Corn 

R. J. Bennett 1 July Corn 

James Bang 1 July Corn 

E. J. Smith 1 July Corn 
Page 2 

Customer Quantity Commodity 

To Buy To Sell M. J. Brierty 2 July Corn 

 

In executing the said orders, the said John W. Lamb, acting as broker on both 

sides of each trade, took the opposite side of each of such orders for his own 

account without the prior consent of such customers. 

5. On April 1, 2, 4, 5, 6, 7, 8, 9, 11, 12, 13, 14, 16, 18, 19, 20 and 21, 

the said John W. Lamb had in his possession a total of 51 orders to purchase and 

47 orders to sell various commodities for future delivery for customers of the 

said Miller & Lamb. In executing the said orders, the said John W. Lamb. on the 

dates above set forth, acting as broker on both sides of each trade, took the 

opposite side of each of such orders for his own account without the prior 

consent of such customers. 

6. On April 1, 1949, the said Lewis E. Strauss had in his possession an order 

to sell 1000 bushels of May wheat for future delivery for the account of Adolph 

Pfeifer, a customer of the said Miller & Lamb. In executing the said order, the 

said Lewis E. Strauss sold 1000 bushels of May wheat to the said John W. Lamb, 

who purchased the same with full knowledge of the fact that the said Lewis E. 

Strauss was acting for a customer of Miller & Lamb. 

7. On April 2, 5, 6, 7, 9, 12, 13, 18, 20, 21 and 22, 1949, the said Lewis E. 

Strauss had in his possession a total of 11 orders to purchase and 12 orders to 

sell various commodities for future delivery for customers of the said Miller & 

Lamb. 

In executing the said orders, the said Lewis E. Strauss traded with the said 

John W. Lamb who, in each case, bought from or sold to the said Lewis E. Strauss 

with full knowledge of the fact that the said Lewis E. Strauss was acting for 

customers of the said Miller & Lamb. 

8. Harry M. Miller was aware of and consented to the manner in which the said 

John W. Lamb took the opposite side of orders of customers of Miller & Lamb, as 

described in paragraphs 4, 5, 6 and 7. 

9. The transactions described in paragraphs 4, 5, 6 and 7 were capable of 

being used for hedging transactions in interstate commerce in such commodities 

or the products or by products thereof, or for determining the price basis of 

transactions in interstate commerce in such commodities, or for delivering any 

such commodities sold, shipped or received in interstate commerce. 

By reason of the transactions described in paragraphs 4, 5, 6 and 7, the said 

Miller & Lamb and John W. Lamb willfully and knowingly, and without the prior 

consent of customers of Miller & Lamb, became the buyer with respect to the 

selling orders of such customers and the seller with respect to the buying 

orders of such customers, in violation of Section 4b (D) of the Commodity 

Exchange Act. 

In addition to the foregoing facts the said Miller & Lamb, Harry M. Miller, 

and John W. Lamb agree to discontinue all such acts and practices and all other 

acts and practices which are in violation of the Commodity Exchange Act, as 

amended, and the rules and regulations thereunder, and do further specifically 

agree that this stipulation shall be admissible as evidence of acts and 

practices in violation of Section 4b (D) of the Commodity Exchange Act, as 

amended, in any subsequent proceeding brought against the said Miller & Lamb, 

Harry M. Miller or John W. Lamb under the provisions of the said Act. 

Done at Chicago. Illinois 

This 25 day of May 1949. 
Page 3 

/s/Miller and Lamb 

(Miller & Lamb) 

by /s/ Harry M. Miller 

/s/ Harry M. Miller 

(Harry M. Miller) 

/s/John W. Lamb 

(John W. Lamb) 

Witnessed by: 

/s/ Benj. M. Holstein 

/s/William T. Buster 

LOAD-DATE: June 16, 2008 
Page 4