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"Frankly, several of our members have received reports from many sources to the effect that the continental prices at which business is reported to have been closed are subject to rebates of varying amounts. We have no quarrel with the continentals or the British in quoting lower than £9.15.0 by means of the rebate system (as this is what we have been asking them to do for some time to elimi nate the American outsider) if they have some real reason for not wanting a price lower than £9.15.0 to become officially known; but, as partners, we consider that we are entitled to know what they are actually doing, because if what they are actually doing is sufficiently low actually to eliminate the American outsider, then we can properly judge the reports our members are constantly receiving as to prices being quoted by the American outsiders and whether or not they are securing any real volume of business. We would be inclined to stay off the ship steel business for the Scandinavian and Holland markets (except possibly at such times as we are in deficit, and then only to the extent of making up our deficit) so long as we know that we are not being denied the opportunity of taking business which is being lost by the cartel to the Philadelphia district mills. Furthermore, as you well know, the sooner these mills are eliminated from taking business, the better our chances will be of bringing them under control in our own group.

"There is also the thought that after the trial period some of our members are not going to be content to remain in the American party if it ultimately develops that mills ouside the party can secure more tonnage than group members.

"This is one of our most aggravating and pressing problems, and we are wondering if you cannot discuss it frankly with Sir Andrew Duncan toward the end of clarifying the situation once and for all."

Yours very truly,

BETHLEHEM STEEL EXPORT Corp.,

C. E. MASTERS, Assistant to Vice President.

EXHIBIT S-114

THE STEEL EXPORT ASSOCIATION OF AMERICA,
October 29, 1938.

The honorable the EARL OF DUDLEY,

New York, N. Y.

DEAR LORD DUDLEY: In answer to the request which Mr. Elliot sent you and which you transmitted to me by telephone, I am writing this letter with the information which it is my understanding is desired. The names of the Amer ican firms who have become members of the Steel Export Association of America in the heavy steel and sheet groups are as follows:

Armco International Corp.

Bethlehem Steel Export Corp.

Inland Steel Co.

Jones & Laughlin Steel Corp.

National Steel Co. (Weirton Steel Co. and Great Lakes Steel Corp.).
Newport Rolling Mill Co.

Pittsburgh Steel Co.

Republic Steel Corp.

United States Steel Products Co.

Wheeling Steel Corp.

Youngstown Sheet & Tube Co.

The qualifications which have been a part of acceptance of some of the above firms include

(a) Freedom in the sale of iron sheets for drainage products.

(b) Exemption from reporting sales of certain heavy porducts that were sold many months ago but not yet shipped (this applies particularly to approximately 5,000 tons of plates which Armco had sold for Brazil and also to very heavy sales of skelp by Jones & Laughlin for export to Canada.)

(c) Insistence by some of the new members that the reporting period on shipments shall only begin with their membership October 18. This is a very difficult problem and one which will require considerable study and negotiation. It is understandable why certain firms take the attitude they do. Their reasoning is based upon their belief that their oversold position if they begin their reports in June rather than October would cause them either to pay very large sums of money for shipments which they made before becoming members or else it would require them to withdraw from the markets for many months to come.

Mr. Elliot has asked for views of these members concerning obligations outlined in his letter of October 18 to Mr. Todd.

The mere fact that so many of these firms have joined the Steel Export Association alters substantially the basis on which the letter of October 18 was written. Therefore, I am at a loss to know how to analyze the views of these new members as pertaining to that letter. However, in answer to this particular query, I suggest that, in view of Mr. Todd's planned early sailing, he could satisfactorily discuss this upon his arrival in London.

Mr. Elliot's cable to you further asked for the position of the Worth Steel Co. at the latest possible date. I think you are acquainted with the efforts which we are making this week end in attempting to have Mr. Girdler confer with Mr. Worth and some of the other officials of the steel companies in the Philadelphia district. At the present time the situation looks very discouraging, but we hope that the people on the other wide will give the Steel Export Association of America permission to use their discretion in plate prices during the immediate future in order to help clarify this situation, as it seems that this is the only way in which the desired results can be achieved.

This answers, I think, the questions which Mr. Elliot put to you; but if Mr. Todd had been here in New York he might have been able to give you some further ideas. However, to repeat, I think that he will be able to supply any details which are missing upon his arrival in London which will be, according to his plans, at a very early date.

With my hope that you may have a pleasant return voyage home, I am,
Yours very truly,

EXHIBIT S-115

AMERLUX STEEL PRODUCTS CORP.,
New York, October 19, 1938.

Re export agreement with American works.

Mr. H. DIEUDONNE,

Managing Director, Columeta, Luxemburg.

DEAR MR. DIEUDONNE: I confirm my letter of yesterday. I am happy to report that there have been favorable developments since then. Mr. Todd was able to report on the results of his meeting yesterday with the American works, to which I referred in my letter of yesterday.

At one stage of the negotiations everything seemed completely settled, all but for one hitch, with Jones & Laughlin, who were still standing out upon a point, but this difficulty was finally overcome at a very late hour in the evening, and the whole of the 15 American works have now given their signature to adhere to the Steel Export Association of America.

One minor difficulty remains, namely, the fact that one outsider-the Worth Steel Co. of Claymont, Del.-are not covered by the agreement, and two other companies, namely, the Alan Wood Steel Co., of Conshohocken, Pa., and the Lukens Steel Co. of Costesville, Pa.-have made their adherence conditional upon the Worth Steel Co. being brought in.

The Worth Steel Co, are makers of plates and sheets, their plate capacity being 228,000 tons and their black sheet capacity 24,000. We understand that the owners of the Worth Steel Co. are Quakers, and appear to have some objection to sitting around the same table with many of their competitors. Mr. Elliot tells me that it is his hope that Mr. Rentschler, president of the National City Bank, may be able to lend his good offices to bring in the Worth Steel Co. Moreover, Mr. Todd expects that he will be able to make headway with Worth, and he is optimistic that within a short time they will come in, which will then make the adherence of the Alan Wood Co. and the Lukens Steel Co. final.

Mr. Elliot also advises me that he has telephoned this morning to Sir Andrew Duncan, informing him of the success of the negotiations, and that Sir Andrew will pass on the good news to Mr. Meyer and to yourself. For this reason I have not thought it necessary to send you a cable.

I wish to say that it is the opinion of the British delegates with whom I, myself, fully concur, that the principal credit for the final success of the negotiations must go in full measure to Mr. Todd, who has been the only man from the beginning never to lose his optimism. In the second place, credit is due to Mr. Grace, Mr. Fairless, and Mr. Girdler, and their associates, the attitude

in particular of the U. S. Steel Corp.. and the Republic Steel Co. has been helpful throughout.

On our side, there is no doubt that little could have been accomplished without the very able leadership displayed by Lord Dudley as spokesman for both the British and the continental groups.

With kindest regards, I remain
Sincerely yours,

E. LEON.

EXHIBIT S-116

PEAT, MARWICK, MITCHELL & Co.,
LONDON, August 14, 1939.

E. I. A./U. K./U. S. A. Agreement-London Committee.
ENTENTE INTERNATIONALE DE L'ACIER,

Avenue de la Liberté, Luxemburg.

DEAR SIRS: With reference to your telephone call to this office on Saturday, August 12, we note that you are having some difficulty in understanding the cable, and in particular the last sentence thereof, of August 3, 1939, which New York sent to Mr. Todd's office in London, a copy of which was sent to Mr. Dieudonné with our letter of August 10.

As mentioned in Mr. Peat's letter of August 1 to M. Dieudonné, we were informed that the SEA were breaking prices in Scandinavia, and following conversations between Mr. Elliot and Mr. Peat the latter sent a cable to New York as follows:

"Request you protest to SEA on behalf London committee against their refusal maintain plate prices indicated by the committee. Prices they are now quoting advise central bureau who will continue to take all necessary steps meet competition."

The New York cable of August 3 is in reply to this cable of the 1st and is intended as an appreciation of the work of the London committee and of the rea sons for the acceptance by the SEA of the trial period between April 21 and October 30, 1939. We appreciate that the cable does not constitute a precise reply to Mr. Peat's cable of the 1st, but as he had kept M. Dieudonné informed of the progress of events he deemed it desirable that it should be sent on to him.

With regard to the last sentence in the New York cable, we think the meaning intended is, firstly, that Mr. Todd's office in London were instructed to send Mr. Peat a copy of the cable (which they have done) and, secondly, that in reference to matters relating to outsider competition, the American group prefer that minutes of meetings, reports, etc., should refer to "meeting outsider competition" instead of "eliminating outsider competition."

Yours faithfully,

S/ ROD M. PEAT.

PEAT & CO.

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