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domestic patent, the Court ruled that that part of the Berliner patent relating to such a combination of elements covered by separ able claims did not expire with the expira tion of the foreign patent covering such claims. The Court referred to the case of Siemen v. Sellers (123 U. S. 276, 31 L. ed. 153, 8 Sup. Ct. Rep. 117) where it was said that a patent cannot be construed as running partly from one date and partly from another, on account of an attempt to extend it by a new patent merely for a former improvement, and ruled that to treat claims as separable when some of them have expired and some have not, can produce no more confusion than may arise from their being separable because some are invalid, as in the case of a partial infringe ment. Perjury. Contempt Committed by Offering False Affidavits—Judicial Procedure in Cases of Perjury—Fine for Contempt Not Dis chargeable in Bankruptcy—Civil and Criminal Contempt. N. Y. A coal merchant was sued for an alleged debt of $1,174 for coal supplied to him, the plaintiff taking judgment by default. He then presented four false affidavits to Chief Justice O. Dwyer of the City Court in New York, declaring that he had never been served with summons and complaint as re quired by the Code. A referee found that the affidavits were false, and Justice Green then established a new precedent by fining the coal merchant, Koronsky, for the con tempt of court committed by his perjury. "Affidavits of the character made by the defendant," said the Court, "are offered daily in the courts with almost as much ease as the presentation of visiting cards," and asserted a determination to doing everything in its power to stamp out the evil. The defendant then avoided payment of the fine of $1,759.46, and imprisonment for non-payment by going into voluntary bankruptcy on Jan. 20, thus escaping danger of arrest on a judgment in a civil action. But Mr. Yorke Allen, the attor ney for the plaintiff, took the matter before Judge Holt in the United States District Court, for the purpose of securing a ruling that the fine imposed for the contempt was for a criminal and not a civil offense. Judge Holt felt constrained to conclude that by the express terms of the Code of Civil Procedure, sections 8 and 14, the fine was for civil con tempt and dischargeable. Mr. Allen did not stop there, however, but went to the United

States Court of Appeals, where Judges Lacombe, Coxe and Ward in a unanimous opinion rendered May 22 reversed Judge Holt and ordered Koronsky to pay the amount in ten days or go to prison. "Manifestly the offense was one peculiarly against the Court," said the three judges, "and of the sort where the pun ishment of the offender is a vindication of the dignity of the Court." Philippine Islands. Land Titles—Spanish Law. U. S. "If the applicant's case is to be tried by the law of Spain, we do not discover such clear proof that it was bad by that law as to satisfy us that he does not own the land," said Mr. Justice Holmes in his decision in Cariho v. Insular Govt, of the P. /., decided by the Supreme Court of the United States Feb. 23. The question before the court was that of the validity of a native title to land on the Philippine province of Benguet, where no document of title had issued from the Spanish Crown. "Upon a consideration of the whole case we are of opinion that law and justice require that the applicant should be granted what he seeks, and should not be deprived of what, by the practice and belief of those among whom he lived, was his prop erty, through a refined interpretation of an almost forgotten law of Spain." Police Power. Power of Congress Over Aliens—Reserved Powers of States. U. S. Congress did not have the power to enact Act February 20, 1907 (34 Stat, at Large 898, Chap. 1134) $3, making it a criminal offense for any person to harbor for immoral purpose any alien woman within three years after she has entered the United States. This conclu sion was reached in .the decision rendered by the Supreme Court on April 5, in Keller v. United States, 29 Sup. Ct. Rep. 470, L. ed. adv. sheets Oct. term p. 470. The alien woman, whom defendant was harboring, voluntarily came to the United States. The power to punish such an offense was reserved to the states in the exercise of their police power. Acts of Congress are to be liberally construed in order to enable it to carry into effect the powers conferred, but the prohibi tions and limitations on such powers are to be fairly and reasonably enforced. But Justices Holmes, Harlan and Moody dissented, on the ground that an immigrant whose calling at the time of her arrival is unlawful can be kept under the control of