t to suppress them, of more serious consequences by
resort to expedients of even doubtful constitutionality."[420]

In short, what was needed, the Court felt, was a hard and fast line
between the two spheres of power, and in the following series of
propositions it endeavored to lay down such a line: (1) production is
always local, and under the exclusive domain of the States; (2) commerce
among the States does not commence until goods "commence their final
movement from their State of origin to that of their destination"; (3)
the sale of a product is merely an incident of its production and while
capable of "bringing the operation of commerce into play," affects it
only incidentally; (4) such restraint as would reach commerce, as above
defined, in consequence of combinations to control production "in all
its forms," would be "indirect, however inevitable and whatever its
extent," and as such beyond the purview of the act.[421] Applying then
the above reasoning to the case before it, the Court proceeded: "The
object [of the combination] was manifestly private gain in the
manufacture of the commodity, but not through the control of interstate
or foreign commerce. It is true that the bill alleged that the products
of these refineries were sold and distributed among the several States,
and that all the companies were engaged in trade or commerce with the
several States and with foreign nations; but this was no more than to
say that trade and commerce served manufacture to fulfil its function.
Sugar was refined for sale, and sales were probably made at Philadelphia
for consumption, and undoubtedly for resale by the first purchasers
throughout Pennsylvania and other States, and refined sugar was also
forwarded by the companies to other States for sale. Nevertheless it
does not follow that an attempt to monopolize, or the actual monopoly
of, the manufacture was an attempt, whether executory or consummated, to
monopolize commerce, even though, in order to dispose of the product,
the instrumentality of commerce was necessarily invoked. There was
nothing in the proofs to indicate any intention to put a restraint upon
trade or commerce, and the fact, as we have seen that trade or commerce
might be indirectly affected was not enough to entitle complainants to a
decree."[422]

THE SHERMAN ACT REVISED

Four years later occurred the case of Addyston Pipe and Steel Co. _v._
United States,[423] in which the Antitrust Act was success