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Rh which at one time comprised 90% of the industry. But during the last few years of the litigation many new firms started in business without taking out a Selden licence, and some members of the A.L.A.M. either ceased or delayed paying their royalties. The decision greatly strengthened the position of the A.L.A.M.,

15 to 18.—American 1920 closed-car designs (Lincoln).

and the organization of the unlicensed manufacturers, the American Motor Car Manufacturers Assn., dissolved. The Ford Motor Co., however, appealed against the decision of the lower court, and in Sept. IQII the U.S. Circuit Court of Appeals, Second Circuit, reversed the decision. The patent was held valid but not infringed, as Selden's engine was a two-stroke, constant pressure or Brayton cycle engine, whereas the engine used by the defendant (and by practically every other motorear manufacturer) was a four-stroke, constant volume or Otto cycle engine. The judges in their opinion said:

"He (Selden) undoubtedly appreciated the possibility of the motor vehicle at a time when his ideas were regarded as chimerical. Had he been able to see far enough he might have taken out a patent as far-reaching as the Circuit Court held this one was. But like many another inventor, while he had a conception of the object to be accomplished, he went in the wrong direction. The Brayton engine was the leading engine of the time, and his attention was naturally drawn to its supposed advantages. He chose that type. In the light of events we can see that had he appreciated the superiority of the Otto engine and adopted that type for his combination his patent would cover the modern automobile. He made a wrong choice, and we cannot, by placing any forced construction upon the patent or by straining the doctrine of equivalents, make another choice for him at the expense of these defendants, who neither legally nor morally owe him anything."

This decision came little more than a year before the expiration of the patent, and no further effort to uphold it was made. Its name having become a misnomer, the A.L.A.M. reorganized as the National Automobile Chamber of Commerce, which came to be regarded as representative of the entire automobile industry, though the Ford Motor Co. never joined it. All of the national motor-car shows in the United States from that time till 1921 were held under its auspices, and it looked after the interests of the industry also in other ways, particularly through its legal, traffic and patent departments. Similar organizations in other countries are:

Great Britain.—Society of Motor Manufacturers and Traders.

France.—Chambre Syndicate de l'Automobile et des Industries qui s'y rattachent.

Belgium.—Chambre Syndicale de l'Automobile.

Germany.—Verein deutscher Motorfahrzeug-Industrieller.

Racing. During the years 'immediately preceding the World War France had the greatest export business in motor-cars, built up by consistent technical development and skilful sales propaganda, chiefly in the form of road-racing. A series of international races held during the first decade of the century, known as the Gordon Bennett Cup Races, came to an end because the French objected to the stipulation in the Deed of Gift of the cup that in the race each country should be represented by a team of three cars, which gave a country with a small industry practically the same chance of winning as a country with a large industry. In 1911 began a new series of races for the Grand Prix of the Automobile Club of France in which each manufacturer was allowed to enter up to three cars, and there was no limit to the number of manufacturers of any one nation. In fact, the race was not on the basis of national team against national team, but on that of manufacturer against manufacturer. This race was held four years in succession (1911-4) and was revived in 1921. Owing to the continued improvement in engines and the increased speeds made possible thereby, it was repeatedly necessary to reduce the limit on the piston displacement of competing cars. Originally the displacement was limited to that of a fourcylinder engine of no-mm. bore and 2oo-mm. stroke (7-6 litres), but in 1921 the limit was 3 litres.

In England and Scotland racing on the public roads was prohibited, and the only road races in the British Isles were held in the Isle of Man. In the United States a number of important races were held in the East during the early years of the automobile movement, but owing to frequent fatalities a strong public sentiment grew up against them, and race promoters were compelled to shift the scene of their activities first to the South and then to the Middle West and the Far West. Between 1910 and 1914 a number of racing-tracks with high banking, most of them 2$1⁄2$ m. in circumference, were built in the United States after the model of the Brooklands track in England. The first and most successful of these was the Indianapolis Speedway. It was at first attempted to hold races on these tracks at frequent intervals, but they soon began to pall on the public. Later the plan of a single annual race was adopted, European contestants were secured and large cash prizes were offered to the winners, and from that time the Indianapolis races always had an enormous attendance. It is worthy of note, however, that practically none of the large manufacturers of America entered cars in the races held in 1919 and 1920. In earlier years competition in races was regarded as a form of sales propaganda and the expenses were charged to advertising, but the public gradually came to realize that to win a race at close to 100 m.p.h. required an entirely different car from that needed by the average family, and that it would not be safe to base conclusions regarding the quality of a company's stock cars on the performance of its special racing machines. Track-racing then became a form of entertainment, expenses being met out of gate-money.

Shows. An important influence on the rapid development of the motor-vehicle industry must be ascribed to the motor-car shows held annually (except for interruptions due to the World War) in such centres as Paris, London, Brussels, New York and Chicago,