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Monday, December 29, 2014

Fighting Back: Police Countermeasures to Automobile Theft, 1919-1941

One countermeasure involved cleaning up urban slums during the 1930s with feudally funding housing.
One of the first countermeasures to auto theft involved the mailing of information cards. Note the significance of the insurance industry in coordinating early efforts to track down stolen cards.

A NICB file card from 1944.




Fighting Back
            To control rampant automobile crimes, authorities developed scientific means to fight back. As early as 1919, a system of fingerprints to identify automobile owners was proposed. [1] The Federal Bureau of Investigation constructed a vast (for the day) fingerprint database called the National Division of Identification and Information in 1924.[2] Starting with over 800,000 fingerprint records, the database grew to more than 2 million by the end of the 1920s.  With fingerprints filed, classified, and categorized, the next step taken was in the compilation of crime statistics. In 1930 a system of uniform crime reporting began. Of the offenses that were included in what became the monthly Uniform Crime Reports (UCR) was auto theft.  Consequently, what resulted was a comprehensive but imperfect picture of the amount and types of crime committed in towns and cities across the country.  Other measures followed.
            Stolen cars was central to FBI activities well beyond tracking down the common car thief.  For example, when John Dillinger broke out of the Crown Point, Indiana jail, it was his theft of a car and crossing of a state line that brought agent Melvin Purvis into the Dillinger hunt.  And a stolen car matter was often the first case in which a new FBI agent cut his teeth.  Purvis, who began his career with the FBI in Dallas, later recalled in his memoir American Agent how by glancing at phone numbers scribbled on a restaurant wall and with some luck and cunning, he tracked down his first criminal, an elusive auto thief.  It was an episode that augured well for his future as a G-Man.[3]
            Quite different than Purvis' examining the writing on a wall, between 1920 and 1941 police developed increasingly sophisticated means to monitor a more mobile public.  Routine  methods employed in Buffalo, NY, during the mid-1920s included the use of police radio, as well as daily and weekly "hot sheets."[4]  In a similar fashion, Los Angeles police department officers began their shift with a list of stolen automobiles printed the night before.  In 1927, a Toledo, Ohio, officer suggested to his superior a system that was remarkably close to what was ultimately adopted by the Auto Theft Committee of the International Association of Chiefs of Police:
1. Get full report and Description of auto stole. As to date and time when auto was reported stolen. Get correct Motor and serial numbers. And license numbers.
2. After the auto has been out for a period of 48 hours, have Insurance Company put the alarm card out,
3- If not insured, have the owner of the auto order through the Police Dept. where auto was stolen from get out about 250 cars. These to be sent to all Dept. that keep a stolen auto file on autos.
4- These alarm cards should be of regulation size, size 3x5. The card for mailing card be a large card, but should be printed so they can be cut to 3x5. And the Motor number should be in the upper right hand corner. Where it can be seen at once. This will help to speed up the filing and checking of autos. And the name of the make of the auto should be close to the top of the card.
5. The officers should check more autos that they see around town, mostly the autos that have out of town license plates they should check these parties to their bill of sales, or the license slips that they are given by the state.
6- Another way to check stolen autos would be to lift the hoods of autos parked on the streets at night, also could be done during the day, mostly around the larger factories. We located some autos by this method and have apprehended some good autos thieves.  Men that have made a business of selling autos with changed Motor numbers, to some men that they are working with.
7- Every bill of sale and Title form from another State, should be checked to see if the Party filing this auto in the State, has the right auto in his Possession.  It is very easy nowadays to buy a junk auto, and get the title and then steal another auto, and go to some other State and Register this auto.  We have been doing this for one year now, and find it is quite a success.
8- Another way to check on stolen autos is that when a party applies for License plates, to have these autos checked by police department and see that everyone gets a license number must have the auto in his or her. With Proper papers.  I understand they are doing this at  Los Angeles Cal and they have quite a success in get back stolen autos.
8- Every Police Dept. should send out a list of every auto that has been recovered. About once a month. As to keep the files clean of autos that have been recovered.[5]
            Additionally, police developed processes using chemicals and torches to identify fake serial numbers.[6] These destructive forensic techniques enabled investigators to recover filed or ground down motor numbers that were seemingly hidden to the naked eye. Typically the stamping process involved striking a cast iron motor block with a die that deformed the metal, leaving an impression. Physically two zones of deformation resulted, one called the plastic, and another deeper area, the elastic. Even if the number was totally removed from the plastic layer, it still existed in the elastic, and techniques were developed to bring those digits visible again. One popular destructive technique used etching solutions, most commonly Fry's Reagent ( 90 grams of copper chloride, 120 ml of Hydrochloric Acid, and 100 ml of water), that when swabbed on the surface of the damaged meal revealed the erased numbers under reflected light. On a horizontal surface like an engine block a frame of modeling clay was made around the area in question and the etching solution was poured of two to five mm).  A heat treatment method was also quite successful in recovering filed off numbers on cast iron substrates. Using a propane torch, a technician heated the metal to cherry red, which caused the deformed area to bulge above its surroundings.  Marks were thus pushed up, and after cleaning, the numbers stood out in contrast to darker surroundings.
             These developments were subsequently supplemented by enhanced communication technology.   In 1936, it was urged that “every city join the nation-wide network of inter-city radio-telegraph service provided for by the Federal Communications Commission.”[7] “Chattering teletype machines and short-wave radio messages outdistance the fleetest car, while police encircle a fleeing criminal in an effort to make escape impossible.” [8] Without doubt, radio communication made auto theft difficult, but for some thieves strategies to overcome police radios, including using radios themselves, would soon follow. By 1934, according to one overly optimistic and naïve journalist, “auto thieves found their racket a losing one.”[9] In response to mobile crime, governments at all levels grew more sophisticated. Insurance companies responded in kind: “In Chicago, a central salvage bureau, maintained by insurance companies is being established in an effort to wipe out a $10,000,000-a-year racket in stolen parts.”[10] Automobile manufacturers invested in a “pick-proof” lock.[11] From 1933-1936 insurance companies and the government decimated the market for stolen automobiles and stolen parts. In 1934 Popular Science Monthly reported that: “figures compiled by the National Automobile Underwriters Association show that eighty-six percent of the cars stolen in 1930 were recovered while in 1931 eighty-two percent were recovered and eighty-nine percent in 1932.”[12]
            Indeed, urban theft rates experienced a sustained decline throughout the 1930s, suggesting that organization, technology, and perhaps depressed economic conditions were contributing to what amounted to good news. [13]  Along with the end of Prohibition, this optimistic turn was possibly the reason why depictions of stealing cars in Hollywood film prior to World War II tended to play incidental roles in comic or farcical situations.  In films including New Adventures of Get Rich Quick Wallingford (1931), It Happened one Night (1934), Social Error (1935), and Bringing up Baby (1938), the serious side of automobile theft, more characteristic of the tone of the 1920s, was dismissed.
Year
Auto Theft, Offenses known to police, cities over 25,000 in population
1931
119,052
1932
100,604
1933
90,806
1934
88,420
1935
76,3236
1936
66,973
1937
69,227
1938
58,490
1939
56,102

             Yet, the confidence exuded by government crime experts during the 1930s was short-lived.  In sum, to 1941 the combination of technology and organization could abate, but stop arrest the theft of a thing Americans had learned to love. The problem of auto theft in the U.S. resurfaced after World War II with a vengeance. For a time it was an issue centering on youth, first those from the middle class and then from minorities.  Later, professional criminals were a target of law enforcement, but in a cultural climate that increasingly portrayed the auto thief as a hero. After all, the automobile in America was the ultimate freedom machine, and driving proved as exhilarating and liberating for thieves as well for owners.   




[1] “Let the Auto Thief Beware.” Illustrated World, (August 1919), 858. 
[2] J. Edgar Hoover, "The National Division of Identification and Information," The American Journal of Police Science, 2 (May-June, 1931), 241-51.
[3] Melvin Purvis, American Agent (Garden City, N.Y.: Doubleday, Doran & Co., 1936), pp. 27-8.
[4] On radio, including both police radio and public programming, see Kathleen Battles, Calling all Cars: Radio Dragnets and the Technology of Policing (Minneapolis: University of Minnesota Press, 2010), especially pp. 157-176.
[5] Letter, off. Hartung to H. Jennings, n.d. [November, 1927?},University of Toledo, Records, 1899-1937,Toledo (Ohio). Police Dept.,Stolen Auto Record,MSS - 162,File, Correspondence to C. of P. Harry Jennings, 1924-27; James W. Higgins, chief of police, Buffalo, Chairman, "Auto Theft Committee" Int. Ass'n of Chiefs of Police to Harry Jennings, November 4, 1927.
[6] Horst Katterwe, "Restoration of Serial Numbers," in Eric Stauffer and Monica S. Bonfanti, Forensic Investigation of Stolen-Recovered and other Crime-Related Vehicles (Amsterdam: Elsevier, 2006), pp.177-194.
[7]“Catching Auto Thieves,” The American City, (October 1936), 15. 
[8] Sterling Gleason, “Auto-Stealing Racket Smashed by New Methods.” Popular Science Monthly, (August 1934), 13.
[9] Ibid, p.12.
[10] Ibid, p.13.
[11]“Science Fights Crime With New Inventions.” Science News Letter, (March 16, 1935), 164.
[12] Sterling Gleason, “Auto-Stealing Racket Smashed by New Methods,” p.13.
[13]  Federal Bureau of Investigation, Uniform Crime Reports, 16, No. 1 (Washington, D.C.: G.P.O.,1945), p.12.



For more on this topic, see my recently published book on the history of auto theft.

Tuesday, December 23, 2014

Woodbridge ,NJ, Speedway Program, 1934. Who was Adolf Gobel?





So the big question I have is that there I read once of a reference that stated that Gobel was most responsible for the popularity of the hot dog in America. This is the first imd I have found anything on Adolf Gobel. Why so hard to find information on why was perhaps a most important contribution to American popular culture and food?

Joy Riders and Professional Auto Thieves in the U.S. Before WWII


From a National Insurance Crime Bureau Brochure, 1921

Wanted, Robert G. Brady 

Wanted James Roy Brock

From the FBI "Notorious Offenders File -- Gabriel Vigorito."


Joy Riders and Professionals 
Quite different in terms of criminal intent were the activities of the so-called joy rider.  Joy riders stole for thrills. In 1917 Secretary to the Detroit Chief of Police, George A. Walters estimated that ninety percent of Detroit’s auto thefts were performed by joy riders.[1] Joy riders were often groups of young men in pursuit of fun, and had a “taste for motoring.”[2] One author argued that joy riders (in all cases male) had a sexual motivation, “Some young fellow with sporty tendencies and a slim pocketbook wants to make a hit with some charming member of the opposite sex...he thinks an automobile would help him in the pursuit of her affections.”[3] After a joy ride, automobiles were often found damaged and out of gas. Historian David Wolcott has noted that in Los Angeles, “Boys approached auto theft with a surprisingly casual attitude – they often just took vehicles that they found unattended, drove them around for an evening and abandoned them when they were done – but the LAPD treated auto theft very seriously.”[4] Joy riding, usually the act of a delinquent, was so serious that young boys were prosecuted under the Dyer Act of 1919. The Federal government did not draw a distinction between joy riding and professional auto theft until 1930.[5] Congressmen Dyer called for the repeal of his own law, and to convince the U.S. House of Representatives of the need for repeal, he read a letter from the superintendent of a penitentiary:        
Of the 450 Federal Boys in the National Training School here in Washington, nearly 200 are violators of the Dyer Act, with the ages distributed as follows: Two Boys 12 years of age, 6 boys 13 years of age, 19 boys 14 years of age, 31 boys of 15 years of age, 64 boys 16 years of age, 48 boys 17 years of age, 19 boys of 18 years of age, 1 boy 19 years of age, and 1 boy 22 years of age.[6]
            Due to the capricious nature of theft for a joy ride, policemen and journalists surmised that it could be easily prevented: “It is against this class of thief that the various types of automobile-locking devices and hidden puzzles are effective…since the joy rider does more than half the stealing it follows that car-locks are more than 50 percent effective in protecting a car.”[7]
            However, more elaborate means would be necessary to stop the professional thief. Apparently the joy riding problem temporarily declined during the 1930s, but organized gangs emerged as a more serious threat and, in the process, vex authorities.  Car theft gangs or rings could be found in virtually every American urban center during the 1920s and 1930s.
              University of Chicago social scientist John Landesco spent five years during the late 1920s and the early 1930s studying organized crime, including auto theft.[8]  Landesco focused on two generations of youth who were a part of a neighborhood, the ethnic Italian "42" Gang.  One of its members described his experiences in considerable detail.  From small boys who knew each others as playmates to young adults working various rackets, Landesco's work traced the evolutionary nature of criminal behavior. Young men in the "42" Gang started their criminal activities by stealing silk shirts off of clothes lines located in the Western suburbs, only later to graduate to the theft of cars for bootleggers.  In between they shot dice, broke into vending machines ("peanut machines"),and  stole bicycles, car and truck tires, and butter and egg trucks.  Gang members quickly learned that if caught they were to keep quiet, endure beatings, and buy off the cops.  Rocco Mercantonio, a prominent member of the "42" Gang, recounted that his auto theft activities involved stealing cars to order and getting paid “$75 to $200 per car -- Fords $75, Buick or Chrysler for $150, a Peerless and Packard for $200.”[9]
Writers who addressed auto theft from 1915-1938 admitted that the professional thief could not be stopped. Professional thieves employed an array of tactics to steal automobiles. Often chauffeurs, mechanics, and garage men became thieves. Even though locks supposedly prevented theft by joy riders, professional thieves would simply cut padlocks and chains with bolt-cutters.[10] In a May, 1929 article “Tricks of the Auto Thief,” Popular Mechanics described an array of tactics. Thieves stole accessories, unlocked and started cars with duplicate keys, “jumped” the ignition by placing a wire across distributor and coil to the spark plugs, ripped-off car dealerships, and towed cars away.[11]  “Some thieves make a specialty of buying wrecked or burned cars as junk…they receive a bill of sale, salvage parts which they place on stolen cars, and so disguise the finished automobile as a legitimate car for which they have the bill of sale.”[12]One method was called “kissing them away.” It involved an individual breaking into a car, and being unable to start it, a “confederate” would push the stolen car with his own from behind. The car would be moved into a garage or alley and promptly dismantled.[13] Thieves used interchangeable parts to confuse authorities. In 1925, Joe Newell, the head of the Automobile Theft Bureau in Des Moines, Iowa, stated, “the greatest transformation that takes place in the stolen machine is in the clever doctoring of motor serial numbers…this is the first thing a thief does to a car.”[14] Automobiles were branded with a serial number that corresponded to a factory record, a number that preceded what is now known as a Vehicle Identification Number (VIN).  However, thieves used several tactics to change the numbers. The “doctoring” of numbers involved filing down numbers and branding a new number into the car, or changing single digits. In a detailed article entitled “Stolen Automobile Investigation,” William J. Davis noted, “It is possible for a thief to re-stamp a 4 over a 1; an 8 over a 3 where the 3 is a round top 3; a 5 over a 3; to change a 6 to an 8, or a 9 to an 8, or an 0 to an 8.”[15] In Popular Science Monthly, Edward Teale noted that: "the automobile stealing racket in the United States has mounted to a $50,000,000-a-year business. During the first six months of 1932, 36,000 machines disappeared in seventy-two American cities alone. In New York City, $2,000,000 worth of cars was reported stolen in 1931."[16]
            Over time professional auto thieves came up with their own lexicon.  A "Bent" or "Kinky" was a stolen car; "Breezer," an open tourer; "Clean One," a car from which all identifying numbers were erased; "Consent Job," an automobile stolen with the owner's consent for the purpose of collecting insurance; "Dauber," was a car painter who worked quickly; "Dog-House,"" a small garage used as a safe house for stolen cars until they cooled; "Right Guy," a dealer who buys stolen cars; "Slicker," a stolen car newly painted; and finally a "Stranger," a stolen car taken from a distant location. Additionally, auto thieves purportedly had their own proverb, namely "Never steal anything you can't steal right away."[17]
            Gangs developed sophisticated automobile theft operations from the expert driver to expert mechanic.[18] The “clouter” actually stole the car and the “wheeler” drove it to the “dog house.” The thieves were concerned with stealing the popular, middle priced, widely used makes. Gangs often specialized in a certain make or model. One New York gang “scrambled” the stolen automobiles: “a number of machines of the same make and model are stolen at the same time…wheels are switched, transmissions shifted, bodies’ changed, and engines transferred from one car to another.”[19]  Other times gangs would use the “mother system.” Under this system, thieves stole a certain make, had a fake bill of sale made, and changed all of the serial numbers to be identical with the bill of sale. Ultimately, four or five of the same car, with the same serial numbers and bill of sale, existed.[20]
            Rings existed in virtually every major American city during the Interwar years, and several of the more sophisticated organizations had connections in multiple major urban areas as well as business links to affluent suburbs.  With the coming of the Great Depression, desperation caused even the respectable to participate in the gangs, often in leadership roles.  For example, William Stanley Hayes, a 44-year old Yale graduate was arrested in 1930 for acting as a "high-powered salesmen for a gang active in New York, Chicago, and the Connecticut suburbs. Hayes, who claimed to work for two persons higher up in gang hierarchy whom he could not positively identify, joined the ring after his work as a jewelry salesmen had dried up and he found himself several months behind with his hotel rent.  Uncovering prospects, demonstrating cars that were already in stock, or arranging for the stealing of cars to order, Hayes offered stolen vehicles at attractive prices -- some 40% off list value.  With altered license plates and motor numbers, these cars were often difficult to trace. Indeed, it was only by chance that Hayes was caught. As it turned out, an unlucky Hayes happened to be walking down the street when a duped customer, in the company of police, ran into the erudite crook.[21]
            Professional auto theft rings often offered stolen cars to order for its customers.  One well-equipped gang  of three in Brooklyn, for example, used its supply of bogus bills of sale, Motor Vehicle Department forms, and an ingenious "jumper box" to steal and sell some 25 cars in only two or three months. Guaranteeing delivery within 24 hours of order, the trio included a Brooklyn Sanitation Department worker who served as "spotter," while the other two used an assortment of tools to pry open locks and connect starter motors. The "jumper box," which police described as being unique, featured a magneto and wires to connect a vehicle's distributor with its starter, thus by-passing the ignition switch. [22]
            The more sophisticated the gang, the more sophisticated the technology employed and the broader its geographical sweep. [23] One New York City gang stole most of its cars in Connecticut and then brought the vehicles to Manhattan. [24] Another ring took vehicles from the suburbs and then disassembled them in a plant in New York City. [25] If auto parts were not readily disposable or were too bulky to process, they were dumped on what became the site of the 1939 New York World's Fair. [26] In both of the above cases, the rackets were family affairs, employing husbands, wives, and brothers, whose day jobs were car salesmen, chauffeurs, and garage owners.  Finally, there was the New York City based gang that operated in a number of adjacent states and that possessed, among other things, notary seals and a stamping machine. The New York Times reported that this group of car thieves and dishonest dealers had profited some $750,000 in a complex operation involving precisely counterfeited motor and serial numbers as well as the paper and ink for registrations and bills of sale.[27]
            The American mafia certainly had a presence in auto theft activities before World War II, but F.B.I. leadership continued to deny the existence of a widespread tight knit organization of criminals until the late 1950s.  Indeed, as one author has asserted: “J. Edgar Hoover and the FBI on one hand, and the Mafia on the other, grew and prospered together, neither causing the other the slightest anguish. This has been the greatest, most obvious and most inexplicable failure of the FBI.”[28] The success of the Mafia was its ability to gain political protection for its activities, and until that political protection broke down in the late 1950s, it was immune to prosecution and the curtailment of its various illegal activities.[29]
             Hoover's primary target in the years both before and after World War II was undoubtedly in the Mafia circle. In 1936, J. Edgar Hoover penned an article about the gangster and international car thief Gabriel Vigorito (a.k.a. Blah-Blah Blackman). He had amassed a $1,000,000 fortune from automobile theft.[30]   Blah-Blah's Brooklyn-based business marketed his “hot cars” to Persia, Russia, Germany, Norway, Denmark, Belgium, and China.  In 1934, authorities convicted Blah-Blah to ten years in prison, but that would not end a career that extended to the mid-1950s.  Historically, the point is poignant; the automobile trumped not only state lines, but national lines.
            The rise of the global automotive industry paralleled the growth of global theft rings. In 1936, the Roosevelt Administration made a treaty with Mexico for “the recovery and return of stolen or embezzled motor vehicles, trailers, airplanes or the component parts of any of them.”[31] The treaty prompted a convention with Mexico in 1937 to address the stolen automobile problem, a problem which went back to the time of the Mexican Revolution, and intensified after World War II.[32]



[1] Roy Lewis, “Watch Your Car,” 169. W.S. Rowe Chief of Police of Cleveland estimated that in 1916 that a majority or autos were stolen by joy riders.
[2] The All-Conquering Auto Thief and a Proposed Quietus for Him,” 112.
[3]“Two Kinds of Motor Thefts – Real and Imagined,” 50. 
[4]David Wolcott, “The Cop Will Get You,” p.358.   
[5] The official distinction was drawn in Impson v. State, 47 Ariz., 573, 1930. See also William R. Outerbridge et al, “The Dyer Act Violators: A Typology of Car Thieves.” School of Criminology, Univ. of California  (January, 1967), iv-v
[6] Quoted in Jerome Hall, “Federal Anti-Theft Legislation.” Law and Contemporary Problems, 1 (Oct., 1934), 428.  See also “Undoing Dyer,” Time Magazine, (March 24, 1930), 13.      
[7] “The All-Conquering Auto Thief, and a Proposed Quietus for Him.” 112.
[8] John Landesco, "The Life History of a Member of the "42" Gang," Journal of Criminal Law and Criminology, 23 (March-April, 1933), 964-998.
[9] Ibid., 980-84.
[10] Edward C. Crossman, “How Your Automobile May Be Stolen.” Illustrated World, (March 1917), 34.
[11] “Tricks of the Automobile Thief,” Popular Mechanics Magazine, May 1929, 772-773.
[12]Ibid, p.774. 
[13]Ibid, p.773.
[14] “Joe Newell Recovered 630 Stolen Automobiles Last Year,” American Magazine, February 1925, 67.
[15]William J. Davis, “Stolen Automobile Investigations.” Journal of Automobile Investigations, 28 (Jan.-Feb. 1938), 732.
[16]Edwin Teale, “Auto Stealing Racket Now $50,000,000-a-Year Racket” Popular Science Monthly , January 1933), 13.
[17] Atcheson L. Hench, "From the Vocabulary of Automobile Thieves," American Speech, 5(February, 1930), 236-7.
[18] See Thomas J. Courtney, “Hot Shorts,” Saturday Evening Post, Nov., 30 1935, 12. See also William G. Shepard, ”I Wonder who’s Driving her Now?” Colliers, (July 23, 1927), 14.
[19] Edwin Teale, “Auto Stealing Racket Now $50,000,000-a-Year Racket,” p. 96.
[20]“Joe Newell Recovered 630 Stolen Automobiles Last Year,” p. 67.
[21] “Prisoner Says Ring Stole Cars To Order,” New York Times, September 18, 1930, p.1.
[22] Ibid., p.1.
[23] “Auto Gang Seized; Guaranteed Loot,” New York Times, January 13, 1932, p.31.
[24] "Seized as Car Theft Ring," New York Times, October 12, 1935, p.3.
[25] "Held as Auto Theft Ring," New York Times, October 13, 1945, p.25.
[26] "6 Arrests Expose Big Car Theft Ring," New York Times, July 24, 1937, p. 3.
[27] "Big Car-Theft Ring Bared by O'Dwyer," New York Times, January 4, 1942, p. 42.
[28] Fred J. Cook, “Organized Crime: The Strange Reluctance,” in Pat Watters and Stephen Gillers, eds., Investigating the FBI (Garden City, New York: Doubleday & Company, 1973), p. 140.
[29] Thomas A. Reppetto, Bringing Down the Mob:  The War Against the American Mafia (New York:  Henry Holt, 2006, pp. 8-9.
[30] J Edgar Hoover,   “Bla-Bla Blackman.” American Magazine, (September 1936), 32.
[31] Mexico—providing for the recovery and return of stolen or embezzled motor vehicles, trailers, airplanes, or the component parts of any of them: message from the President of the United States transmitting a convention between the United States of America and the United Mexican States for the recovery and return of stolen or embezzled motor vehicles, trailers, airplanes, or the component parts of any of them, signed at Mexico City on October 6, 1936 (Washington: G.P.O., 1937).  The Bush Administration made similar treaties with Panama (2000), Honduras (2001), and Guatemala (2002).
[32] Convention with Mexico providing for the recovery and return of stolen or embezzled motor vehicles, trailers, airplanes, or the component parts of any of them: report to accompany Executive A, 75th Cong., 1st sess. (Washington: G.P.O., 1937).