Moore Business Forms, Inc. v. Federal Trade Commission

DANAHER, Circuit Judge

(concurring).

I think the opinion correctly asserts that when the challenged subpoena is ranged with the complaint we “can not” say that information as to price concessions is plainly irrelevant to the charge set forth in Paragraph Five of the complaint. The uncontroverted affidavit of counsel for the appellant makes a strong case for possible oppression and hardship.1 It is my understanding that in response to questions from the bench during argument Commission counsel took the position that it would not insist upon detailed compliance with subpoena specifications 6 and 7, here challenged. Rather, Commission counsel stated, as I understood him, that the Commission would be willing to accept appellant’s records in the form in which they heretofore have been kept. The Commission, in short, has no desire to be unreasonable. I think that is a proper attitude, no more than should be expected from an agency possessed of such vast powers in this field as have been *190reposed in the Federal Trade Commission.

Since we do not have findings by the District Judge, we “can not” assume that he expected anything less than full compliance with the exact terms of the .specifications. I would not give the order such sweep but I vote to affirm on the ground that compliance with specifications 6 and 7 will be deemed adequate if the appellant supplies the required information in the form in which it has been kept in appellant’s records.

. Cf. Hunt Foods and Industries, Inc. v. F. T. C., 286 F.2d 803, 810 (9 Cir. 1960), cert. denied, 365 U.S. 877, 81 S.Ct. 1027, 6 L.Ed.2d 190 (1961).