Indiana daily times. [volume] (Indianapolis [Ind.]) 1914-1922, 1921-06-23

said territory and by threats Of price
cutting and by wrOnRfulIy hiring
away of Its and their employees, either
force such competitor to sell ice
at the price fxed by these defendants
or go out of business.
by wrOngfulIy and unlawfully re-
quiring of all ice peddIers and deal
ers retailing said ice that they agree
to abide by the price fiXed by these
defendants and to not sell any Ice
at a price lower than that fixed by
these defendants and to purchase the
Ice of only such defendants as con-
troll the territory where said peddler
or dealers so delivers said Ice, and
IL said peddler or dealer refuses to
so agree as to price and territory,
then defendants carrying out said
combination, scheme and understand
ing, refuse to sell any ice to such
peddler or dealer. who must either
purchase at defendants price or go
out of business
CHARGES PLANTS CLOSED
DURING STOCK SEASON.
That defendants in carrying out
Of said agreement, combination, con
spiracy, scheme, understanding aud
design to control. the manufacture
of ice In said territory pursued the
following course: Certain OF said de-
PENDANTS agreed to not operate their
plants at certain seasons so as not 20
accumulate a surplus during cool
seasons when the demand is small to
be drawn on during hot seasons when
the demand Is great, and they there
by pave the way in advance for per-
lodic Ice famlnes during which GUS
toners are compelled to submit to
extortionate prices in order to avoid
great loss of perishable food and mer-
chandise.
THAT said defendants, pursuant to
said agreement, only manufacture
such quantity Of ice as will sell at
the high and exorbitant price so
fixed by them and at such n price as
IS not justified by the cost of ma
terial and labor and that said exces
sive price is maintained az the result
Of said agreement, combination and
understanding.
CHARGES AGAINST
STANLEY WYCKOFF.
1.-THE complaint further charges that
as a result of said unlawful agree
ment, combination. scheme, under
standing apd practice the retail price
to the ice consuming public Of Indi-
annapolis is kept at 60 cents per hun
dred pounds when If free and unlim-
tied competition existed between these
defendants and others wishing to en-
gage in said ice business the retail
price would be much less per hun
dred to the consumer and still pay a
reasonable profit to the manufac
turer; that as a result Of said unlaW-
full and wrongful conduct the ice
consuming public Of Indianapolis Is
paying an exorbitant and extortion-
ate price for ice to their great loss
and damage
your informant further shows that
the price fixed and controlled by
these defendants in indianapolis is
communicated by defendant Stanley
WyckOff, as executive secretary of the
Indiana Ice Dealers Association to
all members of said association in the
State Of Indiana, composing a major
ity of dealers in Indiana, who, by an
agreement and understanding with
these defendants, agree and do sell
their ice at a price not lower than
that sold in Indianapolis by these
defendants. That said Stanley Wyck-
off is a party to said agreement and
understanding and helps to fix and
maintain the price Of ice in the I'M
lawful manner aforesaid.
THAT other persons who other
wise would be willing and anxious
to enter said territory and establish
themselves therein as independent
dealers and engage in the retail Of
ice in free, open aud fair competi-
ton with all other dealers and re-
tailers are being prevented from do
ing so on account of said combina-
tion and on account Of the refusal
of the defendants to sell ice to any
dealer or retailer who would not
agree to maintain the price fixed by
them as a result of said unlawful
agreement, combination, conspiracy,
scheme and understanding aforesaid.
That said city of Indianapolis is
a city of 325.O0 inhabitants and on
account Of and as a result of said I'M
lawful agreement, combination and
understanding the residents thereof
are forced to pay the exhOrbitant re-
tail price demanded by these defend
ants on account of the fact that the
defendants herein dominate and con
troll the supply of ice to the consum-
ers and said residents must either
pay said price as fixed by defendants
- -. 4.