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STATE OF RHODE ISLAND PROVIDENCE S.C_________ STATE OF RHODE ISLAND, by and through PATRICK C. LYNCH, Attorney General, . Plaintiff, v, . LEAD INDUSTRIES ASSOCIATION, !NC.,etaL, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) SUPERIOR COURT Civil Action No. 99-5226 AFFIDAVIT OF JAMES C. BURROWS COMMOllWEALTH OF MASSACHUSETTS COUNTY OF SUFFOLK , ) ) ss.: ) JAMES C. BURROWS, being dulysworn, deposes and says: Qualifications and Assignment X. I have been.President and ChiefExecutive Officer ofCharles River Associates ("CRA"), an economics consulting group headquartered in Boston, Massachusetts, since 1995. IfirstjoinedCRAin 1967 and subsequently managed the firm's litigation and regulatory analysis services between 1987 and 1995. One ofmy areas offocus for the past 37 years has been foe economic analysis ofminerals and metals industries; during my career I have performed or supervised hundreds ofeconomic . studies ofminerals and metals commodities. I have performed these studies for more than a dozen governmentagencies - including foe Environmental Protection Agency N50694 `n*.V.3.^*v" &:?^L`&`~:.: :CV* ("EPA"), the Occupational Safety and Health Administration ("OSHA"), and tiie General Services Administration ("GSA") - as well as for a large number ofmajor domestic and foreign producers and consumers ofminerals and metals commodities. Several ofthese analyses have dealt with the lead industry in general; several have concerned the lead pigments portion ofthe overall industry. X obtained a PhD. in economics from the Massachusetts Institute ofTechnology in 1970. I have been the author or co-author ofsix books, fourofthem on topics in mineral economics, Sr addition to my work in mineral economics, I have worked as an economics expert in a number ofantitrust and merger proceedings, have conducted research in connection withthe economics ofa number of other industries, and am well acquainted with the concepts of"market structure, behavior, and performance" as they have been used in a variety oflegal contexts. My curriculum vitae is attached as Exhibit A 2. In affidavits for other lead pigment cases, I identified, to the extent available . historical sources permit, non-defendant firms that produced leadpigments during the period from 1900 to 1970 (non-defendants differed somewhat from case to case because the lists ofdefendants were not the same across all the cases). As explained more folly below, this affidavit will present information from readily available public sources . identifying non-defendant lead pigment producers. 3. Counsel has instructed me to adopt as the relevant time period for my investigation the years 1900 to 1970. Paint containing lead pigment was commonly used in residential applications throughout the United States for many years before 1900, extending well back into the 19th century. Ofthetotal production ofbasic lead carbonate 2 DUP150147319 during fee whole ofthe 1900-1970 period, more than 60 percent was produced in the 1900 to 1927period alone. The use ofleadpigments for residential print later declined due to, among other factors, the general economic downturn of the Great Depression, die diversion oflead supplies to more essential military applications during World War n, and the growth in fee production and use ofalternative non-leadpigments. The use of ' lead pigments in residential interior paint was further curtailed by the adoption by fee . American Standards Association in 1955 ofa voluntaryindustry standard limiting the lead content ofsuch paint to 1 percent by weight. Although this affidavit will focus principally on twentieth century producers, it also will identify certain firms known to have produced leadpigment prior to 1900; fee available data for yeans prior to 1900 are limited. Approach 4. The objective ofmy investigation was to identify companies other than ' Defendants feat produced lead pigments ofthe types that were sold for use in making residential paint. In compiling a list ofsuch companies, we have relied on recognized public sources ofinformation, described more felly below. Findings - 5. Leadpigments made byU.S. producers dining the relevantperiod included lead carbonates, lead sulphates, leaded zmo oxides, lead chromates and molybdates, red lead, orange mineral, and litharge. The first three ofthese are white pigments. The others are colored pigments that, when used to make paint; sawed to tint fee paint or impart corrosion resistance characteristics. Forresidential purposes, red leadwas used 3 DUP150147320 primarily in paints applied on household metal surfaces such as radiators, heating pipes, and exterior railings. litharge, in addition to its use as apigment, was used as a drier iu a wide variety ofpaints and, in some instances, as a rawmaterial for making chrome pigments. AH ofthe pigments described above were used to manufacture household paints. 6. In addition to residential applications, paints containing these lead pigments were used in commercial, industrial, marine, military, and other government applications. 7. In addition to their use in paints, these lead pigments were used fat non-paint applications, such as ceramics, batteries, linoleum, and cement. 8. Attached as Exhibit B is a table identifying firms other thanDefendants that manufactured lead pigments during the indicated years. The information reflected in Exhibit B was derived from the types ofsource materials regularlyrelied upon by industrial economists to determine what companies historically produced particular products. The sources relied upon in compiling Exhibit B include the following: The annual Mineral Resources published by the United States Geological Survey through 1931, succeeded by the annual Minerals Yearbook published by the United States Bureau ofMines contained, during.certain years, tables identifying, by firm name and location, companies that produced lead pigments ofcertain specified types. * A recognized earlier treatise on the lead pigment industry, published iu 1909. Clifford Dyer Holley, The Lead and Zinc Pipments (1909). 4 DUP150147321 * The findings offact by the Federal Trade Commission in a case concerning competition in the lead pigment industry. In re National Lead Co.. 49 F.T.C. 791 (1953). - * Henry A. Gardner, Physicaland ChemicalExamination ofPaints, Varnishes, Lacquers, and Colors, 701 ed, 1935. Oil, Paint and Drug Reporter, Green Book ForBuyers. Company Advertisement: Sears Roebuck & Co. 9. All but one ofthe source materials relied upon to identify lead pigment producers listed in this affidavit are readily available publicly; the Sears Roebuck and Company Advertisement is attached as Exhibit C. ' 10. The list of lead pigment producers set forth in Exhibit B is confined to known ' domestic producers. Lead pigments were also imported into the United States. The volume ofimports varied. Although die volume oflead pigment importswas relatively small in comparison to domestic production throughout most ofthe relevant period, after the Korean War imports grew to levels exceeding 5 percent ofdomestic production. i 5 DUP150147322 Sworn to before me this A day ofApril, 2005 'tary Public Mycommissionexpires 7?/9S/7/ MARY JEANNE LUCHKOV1TZ NOTARY PUBLIC COMMONWEALTH OF MASSACHUSETTS My Co(mission Expires Aug. 25,2011 James C. Borrows 6 DUP150147323 EXHIBIT A \ t N50694.01 DUP150147324 Exhibit A JAMES C. BURROWS--President and Chief Executive Officer Ph.D. A.B. Economics, Massachusetts institute of Technology Economics, Harvard College . Dr. Burrows, Director ofCRA's litigation and Regulation. Group until he became President ofCRA, has extensive experience managing and performing economic and financial analysis relating to antitrust and other litigation. He has considerable experience as an expert witness and in economic support oflitigation-related cases involving antitrust, valuation, international trade, transferprice, commodity and futures market, and contract dispute issues. In addition. Dr. Burrows is an authority on fits economic analysis ofnatural-resource-based industries. PROFESSIONAL EXPERIENCE Finance and Valuation Dr. Burrows has considerable expertise in financial analysis and valuation. He directed all ofCharles River Associates' work on behalf ofthe Penn Central Corporation in connectionwith litigation over the valuation ofPenn Central properties transferred to Comall. CRA's research in this case spanned a period offive years and averaged 10 to 20 person-years of effort each year. The work included forecasting the earnings ofrail lines within the Penn Central system, the market value ofNortheast Conrail commuterlines, real estate, and roiling stock, equipment, and scrap. The research included detailed analysis and forecasts oflabor productivity under differentprospectiyescenarios. Hus workwas necessary both to evaluate the net present valueofcontinuedrailuse properties and to analyze the impact on Penn Central asset value oflabor agreements. Dr. Burrows has directed numerous valuation efforts in connection with mergers and acquisitions. He submitted an affidavit regarding the value ofPillsbury in Grand Metropolitan v. PUlsburr. He prepared valuation testimony for Vitro in connection with its acquisition ofAnchor Corporation. In additionto independently analyzing the values ofthese companies. Dr. Burrows provided a critique ofthe methodology employed by the investment bankers. Dr, Burrows wasthe Officer-in-Charge for a project done for a major corporation intire iron and steel business in which CRA analyzed diversification possibilities. CRA identified approximately 1,000 potential acquisitions, Uhder.Dr, Burrows' direction, tins list was narrowed down.to 20 companies, and estimates ofthe values ofthese companies were made. .. A-l DUP150147325 As file Officer-in-Charge, Dr. Borrowslias supervised CRA's identificationand valuation. Dr. Burrows supervised a project for a company in the ceramics business interested in diversifying. In addition to identifying acquisition candidates, CRA provided estimates of acquisition prices. . Dr. Burrows participated in a project for a major Australian resource company evaluating tiie Worth ofmineral deposits that the company had discovered. He assisted in identifying joint venture partners and in the negotiations by determining both the value each partner would bring to the venture and how cash flows should be divided. Dr. Burrows has recently directednumerous valuation efforts in connection with litigation cases. UnderDr. Burrows direction, CRA valued a 27 percent block ofstock heldby the Conrad Hilton estate In probate litigation; aminority interest in a land development corporation with a value ofabout three billion dollars; a chain ofretail furniture stores; and a resorthotel/restaurant Dr. Burrows wasthe Ofticer-in-Charge for a study on the cost ofcapital for coal mining companies done for tire Bureau ofLand Management in connection wife the setting of lease rates. ' Antitrust . Dr. Burrows has considerable expertise lathe application ofeconomic analysis to issues in antitrust He provided expert testimony in Copperweld v.Imetal. He prepared a report for submission to tiie Federal Trade Commission on the effects on competitionin pulpwood ofGeorgia Pacific's acquisition of GreatNorthern Nekoosa. He has also had significant substantive involvement in a number ofantitrust cases in a range ofindustries, including various metals, bank credit cards, ATMs, and the music business. He has worked on a number ofother cases involving analysis ofthe competitiveeffects of mergers, including the acquisition ofAnchor (Hass by Vitro and file merger ofthe polypropylene assets ofRoyal Dutch Petroleum and Himont Industrial Consulting For 20 years. Dr. Burrows supervised all CRA's work in the metals and mineral industries, including studies ofvirtually all ferrous and nonferrous industries, including aluminum. Among these projects were CRA's multiclient studies ofcobalt, silver, nickel, molybdenum, tungsten, tantalum, columbium, vanadium, titanium, and chromium. Dr. Burrows has directed several majorprojects analyzing fertilizer markets. The first ' was on behalf ofa group ofprivate firms in connection with a litigation-related project The secondproject was a study tor a group ofprivate firms on the effects ofgovernment policies on the markets forfertilizer, pesticides, and other products sold to agricultural users, . '` ' A-2 DUP150147326 Dr. Burrows supervised studies for fits Lead Industries Associationassessingthe impacts ofEPA and OSHA.regulations on the lead industry. Both projects culminated ia Fortiie Board ofDirectors ofamajorminingcompany, Dr. Borrows supervised a comprehensive strategic audit, encompassing analysis ofthe process oftire five-part investments review ofthe 15-yearcorporate plan, analysis ofthe economic and engineering feasibility ofthe firm's projects, review ofthe organizational staxstae, and review ofInvestment valuations and opportunities. Fora private client. Dr. Burrows supervised an analysis ofcommodities and preparation offorecasts in a major regional commodity output and freight forecasting study. The project evaluated alternative macroeconomic regional forecastingmodds, studied how ' freight derives fromregional industrial activity, and determined probable model choices. Dr. Burrows supervised a major industry study ofthe automobile market involving a detailed analysis ofthe demand for different types ofautomobile andthe effects of changes in international trade policies. This study was done for the US Department of labor. He also directed a similar study ofthe truck market for aprivate client Policy Analysis Dr. Burrows directed aproject to analyze the tradeoffbetween public and private oil stockpiling, and to analyze tire impacts ofdifferentpolicy measures on the level of private stocks. ' Dr. Burrows is also experienced ra.regkraal economic development, having directed a study ofthe determinants ofcounty employment, by industry, for use in assessing public facility requirements. This study was undertaken forthe US Department ofCommerce. Forthe Office of Science and Technology, Executive Office ofthe President, Dr. Burrows directed a major Study--one ofthe landmarks in its field--ofthe oil Import quotaprogram. In this study, CRA established a framework for evaluating the costs and benefits ofthe program to the US economy. ' For tire Environmental Protection Agency, Dr. Burrows supervised a forecasting study of Ihe future supply availability and production costs ofvarious grades ofsteam,and metallurgical coal The coal under consideration was from low-sulfur fields in West Virginia and was to be consumed in process, beat, and utilityuses. Supply was projected, by minetype, under various assumptions about government policy and regulatory constraints. A mixed model* based partly on engineering estimates and partly on econometric analysis, was developed to forecast coal mining costs given different geological characteristics. . Dr. Burrows supervised a project for theUS Department ofEnergy Office of Conservation to conduct research on residential energy conservation tax incentives and to evaluate the costs and benefits oftax incentives designed to encourage oil conservation. A-3 DUP150147327 SELECTED PUBLICATIONSAND PRESENTATIONS Boohs PolityImplications ofProducer*CountrySupplyInterruptions. With M. Klass, S. Beggs, R. Landis, G, Debartdo, and T, Cooley. NewYork: PrasgerBoohs, 1978. Aluminum and the IBA; An IndustryAnalysts. With D, Woods, New Yoric: Praeger Boohs, 1978. IndustrialLocation in the UnitedStates. With C. Metcalfand J. Kaler. Lexington, MA: Heath-Lexington Books, 1971. Cobalt: An IndustryAnalysis, Lexington, MA: Heath-Lexington Books, 1971. Tungsten: An Industry Analysis. Lexington, MA: Heath-Lexington Books, 1971. AnAnalysis ofthe UnitedStates OS ImportQuota. With T. Domencich. Lexington, MA: Heath-Lexington Books, 1970. Articles "Mineral Industry Recovery: Short and Long Terra," Best Shot (Winter 1983). "Charles River Associates Analyzes the Tungsten MMksV'AmericanMetal Market (April 1975). "Charles River Associates Analyzesthe SilverMarket" American MetalMarket (April 1974). `The Determinants ofIndustrial Growth at the County Level: An EconomicAnalysis." Essays in Regional Economics. Editedby J. Meyerand L Kahn. Cambridge, MA: Harvard University Press. Conference Papers `Mineral Industry Recovery: Short and Long Term," Presented at American Mining Conference, Las Vegas, October 1982. "Planning for SilverRequirements," WithR. Pittman, P, Katrak, M. Zur-Szpiro, and J.Agarwah Presented at International Precious Metals Institute Conference, June 1983. "Critical Materials: Supply and Demand." WithB, Reddy and F. Katrak. Presented at Industrial Liaison Program Symposium on Critical Materials, Cambridge, MA, ' November 8,1979. A-4 DUP150147328 ``Econometric Models of Metals Markets: A Comparative Survey." 'With M. Lonoffand B. Reddy. Presented at theResources for the Foture/EPRI Conferenceon Natural Resonrce Prices; Washington, DC, June 29,1979. . "Econometric Techniques as an Aid to Technical Decision-Making" WithEL Wise. Presented at International Research Meeting,NewYoriq December IS, 1978. "Charles River Associates Models ofMetal Markets." WifeM. Lonoffi. Presented at Ford Foundation Conference on Stabilizing World Commodity Markets: Analysis, Practices and Policy, Arlington, VA, March 17,1977. "Future Problems InNonfuel Mineral Supplies." Presented at CRA Conference on Future Problems inMinerals and Energy Supply, Boston, October3,1977. "Technological and Nontechnological Responses to International Cartels: Bauxite, Petroleum, and Other Minerals." Wife M. Klass. Presented to American Institute of Chemical Engineers, September 1976. "Econometric Supply/Demand Models." Presented atNSF/RFF, Minerals Modeling Seminar, Washington, DC, Februaiy 13,1975. "The Use ofEconometrics in Microeconomics" Presented at MITIndustrial liaison Conference, Cambridge, MA, November IS, 1971. "The Costs and Benefits ofthe Oil Import Quota." Presented to fee Southern Economic Association (to be included in a bookon US oil policy, edited by E. Erikson), November 13,1970. Testimony in the Past Four Years v Testimony on behalfofperitioners^Km-MeGce Chemicals LLC and Chemetals, Inc), ITC hearing in fee matter ofElectrolytic Manganese Dioxide from Greece and Japan, injury review investigation, Inv. Nos, 731-TA-406 & 408 (Review), March2,2000. Testimony in support ofMotion for Preliminary injunction for Elkern Metals Company, et al.. Plaintiffs, v. United States, et al.. Defendants, United States Court ofInternational Trade, April 19,2000 in fee matter bf"Fexrosilicon from.Brazil, China, Kazakhstan, Russia, Ukraine and Venezuela". A-5 DUP150147329 EXHIBIT B N50694.02 DUP150147330 *\ EXHIBIT B U.S. PRODUCERS OF LEAD PIGMENT OTHER THAN DEFENDANTS Firm and location (Ifknown) American Chemet Corp. East Helena, MT Lead pigment(s) produced Leaded zinc oxide American Zinc Lead Co. (U.S. Reduction & Refining Co.) (U.S. Smelting) Canon City, CO Leaded zinc oxide Years listed 1953,1954, 1955,1956, 1957,1958 1900-1901 1901-1904 1906-1908 Source of Information* MYB 1953-1958 Holley 189 MR 1901-1904 Holley 189, MR 1907,1908 American Zinc, Lead & Smelting Co. (four locations in OH, IL, MO, NY) Leaded zinc oxide 1920,1921 Green Book, 1920, 1921 Andrews Lead Co. Long Island City, NY Red lead/litharge 1931,1932, 1933,1934, 1935,1939 MR 1931 MYB 1932/33, 1934,1935,1939 Anspacher Siegle Corp. Bertha Mineral Co. Anstinville, VA Lead chromate Leaded zinc oxide 1935 (at least) 1910-1924 Gardner A1305, A1315-17 MR 1910 MR 1924 Bunker Hill Co. Seattle, WA Red lead/litharge 1958 MR 1958 Carter White Lead Company Chicago, IL Omaha, NE (acquired by NL in 1906) Basic lead carbonate Prior to 1906 FTC findings offeet, 49 F.T.C. at 824 Eagle White Lead Company Cincinnati, OH (consolidated with Picher Lead Company in 1915) Basic lead carbonate 1909 Holley, 33 B-l DUP150147331 firm and location (if known) Eagle-Picher Lead Company Cincinnati, OH Lead pigment(s) produced Basic lead carbonate East St. Louis, EL East Chicago, IN Eagle-Picher Lead Company Joplin, MO Galena, KS ' Basic lead sulphate Eagle-Picher Lead Company Cincinnati, OH Red lead, orange mineral, litharge Newark, NJ Joplin, MO East St. Louis, IL Galena, KS Years listed 1915,1919 1933,1938, 1945,1946 1922-1932 1946,1953, 1954 1915,1919 1933 1928-1933, 1938,1945, 1946 1919-1932, 1945,1946 1919-1933, 1945,1946, 1953,1954 1919-1933, 1945,1946, 1953,1954 1922-1933 1938,1945, 1946,1953, 1954 Source of information* MR 1915,1921, 1922-1931 MYB 1932 33,1934,1939,1945, 1946,1953,1954 MR 1915,1921 1931 MYB 1932-33, 1934,1939,1945, 1946 MR 1921-1931 MYB1932-33,1934, 1939,1945,1946, 1953,1954 Empire Zinc Co. West Plains, MO Canon City, CO Leaded zinc oxide 1921,1922, 1923,1924 MR 1921,1922, 1923,1924 Euston Lead Co. Basic lead carbonate 1921-1924 (acquired by GHdden in 1924) MR 1921,1922, 1923,1924 Evans Lead Company Charleston, WV (acquired by NL between 1931 and 1933) Red lead/litharge Franklin Lead Oxide Co. Franklin, PA Red lead/litharge 1922-26, 1928,1929 [reported as EvansWallower Lead Co.], 1930-31 1925,1926, 1928-1930 MR 1924-1931; acquisition reflected by FTC findings of fact,49F.T.C. at 824 MR 1925,1926, 1928-1930 B-2 DUP150147332  ':'-'li!-:n:f;?:r;^;: '."V. ~:te Firm and location (if known) Fred L. Lavariburg Co. Lead pigments) produced Lead chromate Hammar Brothers White Lead Company East St. Louis, EL (acquired by Eagle-Picher in 1924) Basic lead carbonate Years listed 1935 (at least) 1909 1919-21 Source of information* Gardner A1305-06 Holley 33 as of 1909; MR 1921 Hammond Lead Products Inc. Red lead/litharge Hammond, IN 1933,1938 MYB 1934,1939 FTC findings offeet, 49 F.T.C. at 829 Harrison Brothers of Philadelphia (acquired by duPont in 1917) Basic lead carbonate 1909 1916,1917 Hofley 33 Harshaw, Fuller & Goodwin Co. Cleveland, OH . Red lead/litharge 1925-26, 1928 MYB 1925,1926, 1928 Imperial Color Works, Inc. den Falls, NY Lead chromate (Lead sulphate Lead oxide) 1935 (at least) Gardner A1298 John Lucas Co. Lead chromate (acquired by Sherwin-Williams in 1929) 1935 (at least) Gardner A1302 John R. MacGregor Lead Co. Chicago, IL Basic lead carbonate 1945,1946, 1953 MYB 1945,1946, 1953 Lead Products Co. St. Louis, MO Red leaddithaige 1919-1920 MR 1921 Lewis Lead Works San Francisco, CA Basic lead carbonate 1909 Holley 33 as to 1909 Linklater Co. Montebello, CA Red lead/litharge 1953,1958 MYB 1953,1958 B-3 DUP150147333 Lir LV-;.- iV f'.-.'S-V,.*'' ' : :&&* Firm and location (if known) Matheson Lead Co. Long Island City, NY (acquired by NL in 1912, according to FTC decision) Lead pigment(s) produced Basic lead carbonate; red lead, orange mineral, litharge Years listed Prior to 1912 Source of information* Holley 33,103 Metals Refining Co. Hammond, IN (acquired by Glidden in 1929, according to FTC decision) Red lead, orange mineral, litharge Mineral Point Zinc Co. Depue, IL & Mineral Point, WI Leaded zinc oxide 1925-26, 1928-1929 MR 1925,1926, 1928,1929 1909,1912, 1913,1917 1920 HoHey 177 MR 1912,1913, 1917,1918,1921 Missouri Oxide & Chemical Co. Joplin, MO Leaded zinc oxide 1919-1921 MR 1921 New Jersey Zinc Co. ofPA Palmerton, PA NevinLead Boston, MA Pittsburgh, PA Leaded zinc oxide; Lead sulphate Basic lead carbonate 1935 1949,1953, 1954 1909 Gardner A1210 MYB 1949,1953, 1954 Holley 33 Ohio Zinc Co. Canon City, CO Leaded zinc oxide 1919-1921 MR 1921 Pennsylvania Smelting Co. Carnegie, PA Red lead/litharge 1919-26 MR 1921-1926 Picher Lead Company Joplin, MO (consolidated with Eagle White Lead Company in 1915) Basic lead sulphate Litharge 1910,1912 1914 1910 MYB 1910,1912 1914 MYB 1910 Pioneer Lead Works San Francisco, CA Basic lead carbonate 1909 Holley 33 Rowley (Mild Process Lead Company) St. Louis, MO Detroit, MI Basic lead carbonate 1904-? Holley 85,89 B-4 DUP150147334 Firm and location (if known) Sears Roebuck & Co. Chicago, EL Lead pigments) produced Basic lead carbonate Years listed 1912 Source of information* Advertisement United Color & Pigment Co. Newark, NJ ' (assets acquired by American Cyanamid Ck>. in 1944) United Lead Co. Perth Amboy, NJ (acquired by NL IN 1906) Red lead/litharge; Lead Chromate Basic lead carbonate 1929,1938 (as to red lead and litharge) 1935 (as to lead chromate) Prior to 1906 MR 1929, MYB 1938; as to lead chromate, Gardner A1304, A1306, A1318-19, A1324 FTC decision Western Dry Color Co. WetheriH & Bros. Philadelphia, PA (acquired by NL in the 1930's) Lead chromate Basic lead carbonate; red lead, orange mineral, and litharge 1935 (at least) 1919-26, 1928-31 (as toallHsted pigments) Notes on following page Gardner A1301, A1319 MR 1921,1922 1926,1928-1931; acquisition reflected in FTC findings of fact, 49 FTC. at 824 B-5 DUP150147335 MYB: U.S. Bureau ofMines Minerals Yearbook MR: U.S. Geological Survey, MineralResources Holley: Clifford Dyer Holley, TheLead andZinc Pigments, 1909 Green Book: The Oil Paint & Drug Reporter, Green BookForBuyers Gardner: Henry A. Gardner, Physical and Chemical Examination ofPaints, Varnishes, Lacquers and Colors, 7a ed. 1935 FTC: Findings ofFact In re National Lead Company, The Federal Trade Commission 49 FTRC 791 Advertisement: Page from a Sears Roebuck and Company catalogue ofpaints, catalogued by the Columbia UniversityLibrary as Published Circa 1912, Exhibit C B-6 DUP150147336 EXHIBIT C N50694.03 DUP150147337 WUhlwiBriCwtouftiTOfa. 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' VfcSDMSW SttnrtJtaJUalUnal,SEDsomlitiibaiTCl4ft* * 39,3002347 ssdte*d,so*JiDSe4p, i0O.polaie.Mt........ 8* 38,3002948 2KrlWhBHqai>Wicw3bbw4.iM.,Mi 4JO ** bV Mb30S2340 Obmme 0tn,tta41iiB, ktatqnaHl?.........>, 6I$ 0OI3OX9230O Cgnu* YUlnir&M0,0HIinII2t,,M*T*H.T* .. 89 . 8V09..3300002233E0O1 x(WaiBtastTuiiluloiinna..n..K...,.,...,..............................................................:.. * 8i 79 8 89 8* aa * 8a 8* 10* 6* 8* 8* tOo 8* 99 i'K ' 90 Plotter Pari*. *Wsof*Ityl*bdotest srtilMpridctat &tti nsttajbsls ud Ami! not bo conluwj with tte EteapafnT*to tfiofrp.W30ftd62300 Pete,pitbBttlef*8)333pOteeH..................... ............ ........12*0f05 ' * Whiting, Bo-3002300 2*bWUtets1riiujt*ri4w>JltrWW. teaslLtbotit Wopwafc,I*li>...ls Umoproof Color* for Hating Knbomsno and Whitewash, A.RSsiiinmtnjrviaiiaSBlsiytkaomotlcanoBiDSegvIiKonioi. ' Fa. 8002302 UMoMOmiiK paimi......................................................ss Ko.3002303 masptecfmu,ptrponaAv.................. ......................... ..............Os Ho.30028.64 ItaimtM.liitHmi.,.,...............................................................................21 Ho,30D336S Uaxsmt Fallens pie psead................................ ...............................3o CEMENT COLORS ite* .w..n.ytmekl*., *2,TM semen. jHSjfM) nww"^1*i wmlaS-US 0*3002309 MU|,OI)>ulhrall........... He. 3002321 tod O*lde,e0CHl twd........... 00.3002802 XXtnXldOUSa, SW-lXHOultwnh..,.. . Ho.3002383 toomaaonttahaoeesnidbLinta...... .-te.3002304 .telvnrOxldi,txyjmn!uml>.......... Ho. 8002300 Him* tetter Oates, SMSpwwltemls.. 0*3002803 inaoir. Slappingtwo.........,,...,,, So* ' * 3o 0* So in* 2K fs< 2He 30* 0U ItW 20 St ' ... it 4t -10* it Of* 8tf* (tt Zhih OIL --TMSiHMfWSWEr W^tW-SWTMtwM'"im*tM *'* glL lusawni J&mm. i&SSkk&j&issijak Liquid Vtiftnyiitf Cu t w Coating. .MHdoe .MNIH KM*ntBM . THE FACTS ABOUT . PAINT Bitty builder, costteotor, outltr psmfer, Jownejmsn fainter and imn mtft lbonM raid pagra 18 and JB, Peryesra itagsnumber opoopteLow*li*4(toeniltdy wrong nnflcntnaaing nboot pstnt. Vrtmg tBlonoatlon lias txiea aditrtlwi.liy xasny jnstituUons vlio vert too enthulwtic aboot ttelrxnm and at a cMuepuiM nany people Jutv* been given keortwt &t*i and ixupxtuient about paint*. 17a butt "4t away dews deep*into *1 ptoses <4 tb* paint >]oratios and Iwn untarQisd tbs* sssl&cte. Tor pan cor Baperta bavi bimSb a study of paint* ht every totodisKs tom and we oilor you titreaults ot dudnteateand atady aa thoim t psgea J8 and 18 Tba&t-P02t* ronfcatn Jnlormatloq coopiWd t gsoat expetra and modi labor and axe filled witis toot* invatoaU* to anyone wbo will apply tbem to bli own me. Tobo advantage U tbe eppoitaiU^ to mad end leans, whast we Hhaave ssett downx,uraaaj. q w j l . . atetemant matte iobadted up by iodiopixtabla tents, AVERY" ^"RCHnBCTOR ^ SEABS, BOEBUCE AM CO, CHICAGO, ILLIHOIST DUP150147338