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Commodity Futures Trading Commission 

CEA CASES 

NAME: WILLIAM LUDWIG 

DOCKET NUMBER: 94 

DATE: AUGUST 30, 1960 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: William Ludwig, Respondent 

CEA Docket No. 94 

Complaint and Notice of Hearing Under Section 6(b) of the Commodity Exchange 

Act 

There is reason to believe that respondent, William Ludwig, has violated the 

Commodity Exchange Act (7 U.S.C. 1958 ed., Chapter 1) and the rules and 

regulations made pursuant thereto, and in accordance with the provisions of 

section 6(b) of said act (7 U.S.C. 1958 ed., § 9), this complaint and notice of 

hearing is issued stating the charges in that respect as follows: 

I 

Respondent William Ludwig, an individual whose address is 180 Duane Street, 

New York, New York, is now and was at all times material to this complaint a 

member of the Chicago Mercantile Exchange. 

II 

The Chicago Mercantile Exchange is now and was at all times material to this 

complaint a duly designated contract market under the Commodity Exchange Act. 

III 

At various periods during 1955 and 1956, the respondent traded in egg futures 

on the Chicago Mercantile Exchange through For DeLuxe Foods, Inc., in accounts 

carried in the names of William Ludwig, Edson Eldredge, and Charles Colangelo. 

All transactions in such accounts during such periods belonged to or were 

controlled by the respondent. 

IV 

On each day from June 29 to July 11, 1955, the respondent held or controlled 

a net long position in egg futures on the Chicago Mercantile Exchange in one or 

more of the above named accounts, which position ranged from 33 to 43 carlots in 

a single future. By reason of the fact that such quantities were equal to or in 

excess of 25 carlots, the respondent was in reporting status and was required to 

report to the Commodity Exchange Authority with respect to all transactions 

executed and all open contract positions held or controlled by him, in all egg 

futures on all boards of trade (exchanges) during the said period and with 

respect to all transactions by reason of which the respondent's position was 

reduced below reporting levels, as provided in section 4i of the Commodity 

Exchange Act (7 U.S.C. 1958 ed., § 6i) and sections 5.10, 5.11, 5.12, and 5.21 

of the regulations thereunder (17 CFR, 5.10, 5.11, 5.12, 5.21). 

V 
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On June 29 and June 30, 1955, while the respondent was in reporting status as 

described in paragraph IV, and on July 11, 1955, when the respondent's position 

was reduced below 25 carlots, transactions in egg futures on the Chicago 

Mercantile Exchange were executed on his behalf in two of the above named 

accounts, but the respondent failed to report to the Commodity Exchange 

Authority with respect to such transactions, in wilful violation of the 

aforesaid provisions of the Commodity Exchange Act and the regulations 

thereunder. 

VI 

At various times from August 2 through December 19, 1955, the respondent held 

or controlled a net long position in egg futures on the Chicago Mercantile 

Exchange in the amount of 25 or more carlots in a single future. By reason 

thereof, the said respondent was in reporting status and was required to submit 

reports to the Commodity Exchange Authority as described in paragraph IV. On 20 

days within such period, on each of which days the respondent was in reporting 

status, transactions in egg futures on the Chicago Mercantile Exchange were 

executed on behalf of the respondent in one or more of the above named accounts, 

but the respondent failed to submit reports to the Commodity Exchange Authority 

on 7 of such days and submitted false reports with respect to the remaining 13 

days, in wilful violation of the aforesaid provisions of the Commodity Exchange 

Act and the regulations thereunder. 

VII 

On December 8 and December 9, 1955, the respondent held or controlled total 

speculative net long positions of 74 and 98 carlots, respectively, in the 

December 1955 egg future on the Chicago Mercantile Exchange in the above named 

accounts. By reason thereof, the respondent traded in such future in an amount 

which resulted in positions in excess of the maximum permissible quantity of 50 

carlots, in wilful violation of section 4a of the Commodity Exchange Act (7 

U.S.C. 1958 ed., § 4a) and the order of the Commodity Exchange Commission 

establishing limits on position and trading in eggs for future delivery (17 CFR, 

150.5). 

VIII 

From December 20, 1955, through January 24, 1956, the respondent held or 

controlled speculative net long positions which ranged between 51 and 98 carlots 

in the January 1956 egg future on the Chicago Mercantile Exchange in the above 

named accounts. By reason thereof, the respondent traded in such future in an 

amount which resulted in positions in excess of the maximum permissible quantity 

of 50 carlots, in wilful violation of section 4a of the Commodity Exchange Act 

(7 U.S.C. 1958 ed., § 6a) and the order of the Commodity Exchange Commission 

establishing limits on positions and trading in eggs for future delivery (17 

CFR, 150.5). 

IX 

On each day from December 20, 1955, through January 24, 1956, the respondent 

held or controlled a net long position in egg futures on the Chicago Mercantile 

Exchange in the above named accounts, of 25 or more carlots in a single future, 

by reason of which the respondent was in reporting status and was required to 

submit reports to the Commodity Exchange Authority, as described in paragraph 

IV. On 17 days within such period, on each of which days the respondent was in 

reporting status, transactions in egg futures on the Chicago Mercantile Exchange 

were executed on his behalf in one or more of the said accounts, but the 

respondent failed to submit reports to the Commodity Exchange Authority on four 

of such days and submitted false reports to the Commodity Exchange Authority 

with respect to the remaining 13 days, in wilful violation of the aforesaid 

provisions of the Commodity Exchange Act and the regulations thereunder. 

X 
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On March 22, 1955, a complaint was issued in CEA Docket No. 66, charging that 

the respondent exceeded the speculative limits on daily trading and positions in 

eggs for future delivery on the Chicago Mercantile Exchange during various 

periods in 1954 and 1955, and that the respondent filed false reports covering 

his trading and positions. On April 21, 1955, in response to such charges, the 

respondent submitted a stipulation 

in which he consented to an order directing all contract markets to refuse all 

trading privileges to him for a period of thirty days effective July 1, 1955, 

and such an order was issued by the Judicial Officer on May 11, 1955, applying 

to all trading done and positions held by the said William Ludwig directly or 

indirectly. The respondent, therefore, was aware of his obligations under the 

act and the regulations with respect to speculative limits and reporting 

requirements, and he carried or controlled accounts under various names on the 

books of Fox DeLuxe Foods, Inc., as described above, and caused the execution of 

transactions in such accounts, in order to conceal deliberate and willful 

violations of the act and circumvent the denial of trading privileges imposed by 

the aforesaid order of the Judicial Officer. 

Wherefore, it is hereby ordered that this complaint and notice of hearing be 

served upon the said respondent. The respondent will have twenty (20) days 

after the receipt of this notice of hearing in which to file with the Hearing 

Clerk, United States Department of Agriculture, Washington 25, D. C., an answer 

with an original and five copies, fully and completely stating the nature of the 

defense and admitting or denying, specifically and in detail, each material and 

relevant allegation of this complaint. Allegations not answered will be deemed 

admitted for 

the purpose of this proceeding. Failure to file an answer will constitute an 

admission of all the material allegations of this complaint and a waiver of 

hearing. The respondent is hereby notified that unless hearing is waived, 

either expressly or by failure to file an answer and request a hearing, a 

hearing will be held at 10:00 a.m., local time, on the 25th day of October, 

1960, in New York, New York, at a place therein to be specified later, before a 

referee designated to conduct such hearing. At such hearing the respondent will 

have the right to appear and show cause, if any there be, why an order should 

not be made directing that all contract markets refuse all trading privileges to 

the respondent for such period of time as may be determined. 

It is ordered that this complaint and notice of hearing be served on the 

respondent at least twenty (20) days prior to the date set for hearing. 

Done at Washington, D. C., 

August 30, 1960. 

/s/ Clarence L. Miller 

Clarence L. Miller 

Assistant Secretary 

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