The opinion of the court was delivered by: Austin, District Judge.
1. Plaintiff, Carl Schnell (referred to hereafter as
"Schnell"), is a citizen of Germany, residing at Winterbach near
Schorndorf, Germany. Plaintiff, The Griffith Laboratories, Inc.
(referred to hereafter as "Griffith"), is an Illinois
corporation, having its principal office and place of business in
the City of Chicago, Illinois. Defendant, The Allbright-Nell
Company (referred to hereafter as "Allbright-Nell" or "Anco"), is
a corporation of the State of Illinois, having its principal
office and place of business in the City of Chicago, Illinois.
Defendant, Peter Eckrich and Sons, Inc. (referred to hereafter as
"Eckrich"), is an Indiana corporation having its principal office
and place of business in the City of Fort Wayne, Indiana.
Ownership of Patents in Suit.
2. Plaintiffs are and since the respective dates of issuance
have continuously been joint owners of United States Letters
Patents 2,840,318, 2,906,310, 2,934,120, 2,934,121, and
3,044,514, and United States Letters Reissue Patents 24,683 and
24,764, and all rights of recovery for all infringements thereof.
All of these patents were duly and legally issued on inventions
made by Carl Schnell. With the exception of Reissue Patent
24,683, these patents relate to comminuting machines that
emulsify meat products. These machines are widely used by sausage
manufacturers to produce new and improved meat products. Reissue
Patent 24,683 relates to methods for emulsifying meat products,
which methods are also widely used by sausage manufacturers.
3. Plaintiffs, Schnell and Griffith, brought the following
patent infringement actions against defendant, Eckrich, in the
United States District Court for the Northern District of
Indiana, Fort Wayne Division:
C.A. 1128, filed 2/13/59, involving U.S. Letters
Patents 2,840,318 and 2,842,177;
C.A. 1184, filed 9/30/59, involving U.S. Letters
C.A. 1211, filed 2/8/60, involving U.S. Letters
Reissue Patent 24,764 (a reissue of Patent
C.A. 1229, filed 4/26/60, involving U.S. Letters
Patents 2,934,120 and 2,934,121.
4. On January 14, 1960, defendant, Allbright-Nell, brought a
declaratory judgment action against plaintiffs, Schnell and
Griffith, in the United States District Court for the Northern
District of Illinois, Eastern Division, involving U.S. Letters
Reissue Patent 24,683 (a reissue of U.S. Letters Patent
2,836,825) and U.S. Letters Reissue Patent 24,764 (a reissue of
U.S. Letters Patent 2,842,177). This action was identified as
Civil Action No. 60-C-62.
5. On November 21, 1961, plaintiffs brought the above-entitled
Civil Action No. 61-C-1979 against defendants alleging
infringement of each of U.S.
Letters Patents 2,840,318, 2,906,310, 2,934,120 and 2,934,121,
and U.S. Letters Reissue Patents 24,683 and 24,764.
6. Civil Actions Nos. 60-C-62 and 61-C-1979 were consolidated,
after which plaintiffs and defendant, Eckrich, stipulated for the
dismissal, without prejudice, of the patent infringement suits in
the Northern District of Indiana, referred to in Finding 3,
above. This stipulation provides:
(a) The dismissal shall not give rise to the
defense of estoppel or laches or statute of
limitations with respect to the causes of actions set
forth in the complaints in Civil Actions Nos. 60-C-62
and 61-C-1979, unless such defenses would have been
available without such dismissal; and
(b) The dismissal shall not be considered a
voluntary dismissal under Rule 41(a) of the Federal
Rules of Civil Procedure.
7. The original complaint in Civil Action No. 61-C-1979 was
revised by an order of this Court, dated July 17, 1962. The
revised complaint brought into suit plaintiffs' U.S. Letters
Patent 3,044,514, issued on July 17, 1962.
8. Plaintiffs asserted that defendants, or either of them,
infringe the following patents (PX-2), including the claims
identified with respect thereto:
Patent 2,840,318: Claim 2;
Patent 2,906,310: Claims 1-8;
Patent 2,934,120: Claims 1 and 2;
Patent 2,934,121: Claims 1-24;
Re. Patent 24,764: Claims 1-3 and 5-15;
Patent 3,044,514: Claims 1-15, 17
and 18; and,
Re. Patent 24,683: Claims 1-16.
9. The sausage industry is based on the utilization of the
portions of the carcasses of cattle or hogs which cannot be used
as steaks or hams or pork chops. This material is known in the
industry as trimmings, and is the portion of the carcass that is
left over when the prime cuts are removed. Many types of
trimmings contain gristle and/or hard meat (e.g., rinds and offal
materials) which nonetheless have high protein or nutritional
value when suitably cut.
Cypser 47, 48, 53, 54; Swanson 90, 91, 94-98, 107-110; PX-7;
Turner 147-150, 165; PX-82.
10. Sausage emulsions were produced almost entirely by use of
machines like the Silent Cutter, or chopper as it was more often
referred to. These machines were large, bulky and relatively
slow, and they did not produce the quality of emulsion now
available, nor did they permit the use of many nutritious
portions of the carcass which could not be adequately subdivided
Swanson 80-87; Cypser 47, 48, 53.
11. The Silent Cutter was a standard piece of equipment that
was used by commercial sausage kitchens for many years before
Schnell discovered a meat comminuting machine. It comprised a
doughnut-shaped bowl that turned in a horizontal plane and a
cutting zone with a series of vertically rotating blades. The
mass of meat in the doughnut-shaped bowl was forced continuously
into these vertically acting cutting blades. This reduced the
particle size of the meat and fat products and, with the addition
of moisture that was added to the mix, made a blend. The Silent
Cutter caused a high temperature rise of the meat in a short
period of time. This was extremely undesirable because a high
temperature rise caused a marked variation in the product which
in turn affected the salability of the product. Further this
machine required a batch operation. The cutting blades had to be
continuously kept in a sharp condition for efficient operation
and the knives presented considerable danger to the operator.
Swanson 102-104; PX-5; Turner 116-117, 152-154; Cypser 76; PX-4.
13. Colloid mills were also used, to a limited extent, to
comminute meat. These, too, produced a high temperature rise of
the meat. Further, their tearing action produced an undesirably
14. Commercial sausage kitchens used a grinder, followed by a
chopper (e.g., Silent Cutter), followed by stuffing means and
then treatment in a smoke house. The grinder was used to break
down the large pieces of meat product into a size suitable for
further blending and cutting in the chopper, where moisture and
seasoning were added.
Cypser 46; Swanson 82; PX-4; PX-8; DX-92.
15. This finished emulsion then went to stuffing apparatus
which placed it into casings of a size suitable for frankfurters
or bologna and from there the meat was further cooked or smoked
in the smoke house to produce the finished sausage.
Cypser 46; Swanson 82; PX-4; PX-8.
16. Schnell discovered that he could cut rinds and offal
materials in his early meat comminuting machines in the raw,
uncooked state and still be able to produce a better emulsion
than had been previously obtained with these materials in other
DX-271A, pages 14, 30, 31; DX-271B, pages 136, 145; DX-271C, page
17. He found that he could emulsify nutritious trimmings,
including hard particles, that previously could not be used.
However, with some meat products it was necessary to exert
pressure upon the meat in the hopper in order to force the meat
down to the rotary knives.
18. Later, Mr. Schnell made a further discovery of great
consequence. He was the first to discover and teach that when
meat ingredients were combined in a hydraulic column and
propelled by a rotating knife against a perforate valve plate so
that most of the material propelled to the plate would not pass
through it but would be diverted back for recutting and remixing,
one got an entirely new result.
Schnell 1666-70; DX-271A, page 39; DX-271F, pages 500, 501.
19. Schnell was the first to discover and teach that this
action of the plate made it possible to get better cutting,
better distribution and greater output in spite of the fact that
the hydraulic column put a tremendous drag on the motor and
required a larger motor which caused more heat. The greatly
increased output more than compensated for the extra heat
produced by the large motor so that there was a lower temperature
rise in the product.
Schnell 166-70; DX-271A, page 39; DX-271F, pages 500, 501; Turner
20. The rate of comminution depends upon the toughness of the
meat, the fluidity of the mixture and many other factors. But
even with the toughest meat, the capacity of Schnell's sealed
emulsifier is almost incredible. Eckrich's records show many
instances of treatment of well over 500 pounds of meat per
minute. With conventional high grade sausage emulsions,
comminuting 200 or 300 pounds per minute is now standard with
plaintiffs' and defendants' emulsifiers. The machine introduced a
new problem to the industry, namely, trying to supply the machine
with an adequate rate of feed material which became necessary due
to the markedly
increased rate of comminution. This led to automation of the
Turner 162; Swanson 100-102; Cypser 52; PX-92A and C-R; PX-94A-H.
21. The reason why the comminuting of material like meat is so
greatly improved with the hydraulic column is theoretical in that
one cannot watch what happens to an individual particle of meat.
One can observe only the result in greater capacity, greater load
on the motor, improved emulsification and a limited temperature
Fishleigh 2790, 2810; Schmidt 3564; Turner 160-162; Swanson
100-102; Cypser 52.
22. With the hydraulic column, the pressure of the atmosphere
is employed to maintain continuity of meat material in the
emulsifier. The 14.7 pounds per square inch pressure of the
atmosphere assures that the movement of one particle away from
the knife, after being hit, pulls at least another particle into
Schoenherr 3848-3850; Turner 442.
23. The hydraulic column is essential for most commercial
operations as now practiced. The power requirements are several
times greater when the hydraulic column exists, but the feeding
of meat is difficult without the hydraulic column. In fact,
introducing a few bubbles of air in the entrance of the
comminuting chamber will normally stop any feeding of meat or at
least slow it down to a point where overheating results.
Turner 160-162, 3742-3743; Cypser 71; Schnell 1666-70; DX-271A,
page 39; DX-271F, pages 500-501.
24. In developing his emulsifier, Schnell discovered that
certain other structures in the emulsifier afforded added
advantages in comminuting meat products. Included in such
structures are the particular shape of the propelling knife, the
circulating surfaces that cooperate with the knife and perforate
plate, and obstructing means.
DX-271A, pages 18, 19; DX-271B, page 149; DX-271C, pages 225,
Schnell's Discoveries Revolutionized the Sausage Industry.
25. The Schnell emulsifier revolutionized the sausage
processing industry and permitted, for the first time, the
sausage manufacturers to produce sausage in a continuous manner
rather than in their previous batch-wise operations wherein the
meat had to be manually conveyed from the grinder to the chopper
and from the chopper to the stuffer. The Schnell emulsifier
enabled sausage manufacturers to feed their emulsion through
pipes directly into the pump-type stuffer without any handling.
Manual handling of the meat was obviated and sanitation was thus
Turner 162; Swanson 100-102; Cypser 52; PX-4.
26. In addition, the Schnell emulsifier enabled the sausage
manufacturers to produce a better meat product, enabled them to
produce this superior product at a lower per pound operating cost
and displaced space-consuming and more expensive equipment. More
specifically, the Schnell emulsifier:
(a) Permits the utilization of highly nutritious
animal products not heretofore usable in sausage,
thereby lowering the cost of the sausage;
(b) Produces a finer and more uniform emulsified
product than the meat industry was able to obtain
with existing equipment;
(c) Produces a more presentable and salable
product; that is, a product that looks better to the
average customer and a product that is more uniform
in taste and consistency;
(d) Provides better utilization of equipment
already existing in sausage kitchens. Sausage
kitchens can now produce more in terms of pounds of
product per hour than through their grinder and/or
(f) Provides savings in floor space. The upright
model of the emulsifier occupies much less floor
space than the chopper, which could be eliminated;
(g) Reduces the need for the highly skilled
personnel that was previously required. Prior to
Schnell, chopping of sausage products was a highly
skilled operation. The sausage maker who operated the
chopper was a highly paid individual who had
developed a special skill in knowing when chopping
should be stopped.
Cypser 46-54, 57, 62; Swanson 90, 94-102, 107-110; Turner 162,
163-174; PX-4; PX-9.
Introduction of Emulsifiers in the United States.
27. During the period of from 1956 to the present time, the
Schnell machines have been made by Schnell for Griffith and they
have been sold in the U.S. by Griffith under the name "Mince
Master" machines. These machines substantially correspond with
the structures shown in various Schnell patents in suit.
Griffith 535; Turner 216-284; DX-271B, pages 102-106; PX-1;
PX-10; PX-79; PX-81.
28. After Griffith's "Mince Master" machines were introduced
and first sold in the U.S., Allbright-Nell first made and sold in
the U.S. a copy of the "Mince Master" machine. This copy was
later identified as the Anco "Emulsitator" machine.
29. Emulsifier such as Griffith's "Mince Master" machines and
Allbright-Nell's Anco "Emulsitator" machines produce a smooth,
uniform emulsion which was not obtainable under the old methods
or with the old equipment, in addition to being able to emulsify
materials which could not be used in the past.
Cypser 56, 57, 66, 70; Turner 163-174; PX-9.
30. In the very few years in which the emulsifiers have been
available in this country, the commercial sausage industry now
relies greatly upon this type of machine.
Cyprus 48, 49, 59; Turner 357-359; R. 690; PX-84.
31. Sausage manufacturers have bought "Mince Master" machines
and "Emulsitator" machines because their customers would no
longer accept the type of product they formerly made.
Swanson 92, 99; Cypser 55, 56; Turner 357-359; R. 690; PX-84.
32. In some instances, sausage manufacturers continue to handle
their meat products through both the grinder and the chopper, and
then through either a Griffith "Mince Master" machine or Anco
"Emulsitator" machine. Even with this procedure, they are able to
shorten both the grinding and chopping operations and obtain a
savings in labor.
Swanson 100, 101; Cypser 52; PX-4; PX-9.
33. Important savings are obtained with the use of the Griffith
"Mince Master" emulsifiers and Anco "Emulsitator" emulsifiers.
Cypser 48-52; Swanson 94-98; PX-7.
34. The use of Griffith "Mince Master" machines at Armour and
Company, a company that makes a minimum of 2,000,000 pounds of
frankfurters and bologna per week, was an important factor in
converting within an eighteen month period a loss of $2,000,000
to a profit of $4,000,000 in the sausage department.
36. The ability to employ nutritious meat products not
heretofore usable in sausage emulsion enabled John Morrell and
Company, a manufacturer of meat products, to save as much as 4¢
per pound of sausage.
History of the "Mince Master" and "Emulsitator" Machines.
37. Schnell used in 1954 a comminuting machine with a knife
that rotated upon a perforate plate. This machine was used for
comminuting pork rinds. In the Spring of 1955, Schnell ordered
Huth seals for his meat emulsifier and used them in his
emulsifiers before September of 1955. He found, before July,
1955, that if he covered the exhaust with his hand, he could
obtain a hydraulic column which, however, overloaded the motor
but greatly increased output. Since German requirements did not
call for larger output and the Huth seals were not satisfactory
for general use, Schnell put the matter aside until he obtained
rubber Goetz seals (DX-9) commencing in January, 1956. At that
time he also received a request for larger motors from Griffith's
representative, Mr. Young.
Schnell 1485-88, 1490, 1646-49, 1666-70; DX-271A, pages 14, 30,
31, 36-38; DX-271B, pages 136, 145; DX-271F, pages 500, 501;
PX-125 and -125A; PX-126 and -126A; PX-127 and -127A;
38. Mr. Carroll L. Griffith, president of the plaintiff,
Griffith Laboratories, first learned of the Schnell emulsifier in
January of 1956 from a Griffith salesman, Mr. Young, who was in
39. Griffith first ordered a Schnell emulsifier in January of
1956 and it (PX-81) arrived in this country at the end of April
of 1956. It was powered with an electric motor that was rated at
25 horsepower on 60 cycle current and turned at 3600 r.p.m. The
drive shaft for the knife was not sealed to prevent ingress of
air into the machine during operation.
Turner 120-22, 146; Griffith 524, 525; R. 674.
40. The first Schnell machine (PX-81) that was received by
Griffith was sent to Coronet Packing Company (hereafter referred
to as "Coronet") in Chicago for the purpose of testing and
demonstrating the machine. This particular machine will hereafter
be referred to as the "Coronet machine."
Turner 154; Griffith 525, 526; R. 674.
41. The Coronet machine (PX-81) was demonstrated by Griffith at
Coronet during the National Independent Meat Packer's Association
convention in Chicago during May of 1956.
Turner 154, 155; Griffith 525, 526; Swanson 90, 91; R. 674.
42. The Coronet machine (PX-81) did not produce a hydraulic
column; however, it did produce an outstanding emulsion compared
to anything then available, particularly with respect to
materials such as pig skins and offal meat material.
Turner 146; Swanson 90; R. 674.
43. A slushy mix of skins and ice was fed into the machine
(PX-81) at Coronet during May of 1956. An emulsion was produced
that had a consistency resembling ordinary cold cream. Mr.
Swanson, then with the John Morrell Company, described the skins
as having been made "* * * into smooth, creamy emulsion that
heretofore hadn't been possible to do."
Turner 148-50; Swanson 91.
45. While this Schnell machine (PX-81) was at Coronet, it was
discovered by Griffith that the motor was overloaded.
46. During May of 1956, Griffith requested from Schnell an
emulsifier having greater horsepower. Schnell confirmed this
order the same month. Long before this time, Schnell had used a
seal about the drive shaft of his high speed meat emulsifiers.
Turner 155-156; Schnell 1484; Bihler 1461, 1469, 1470, 1546;
Furthmuller 1722; PX-144 and -144A.
47. In September of 1956 Griffith received from Schnell a
"Mince Master" machine with a more powerful motor and a seal. It
was sent by Griffith to Saratoga Meat Products Company (hereafter
referred to as "Saratoga") in Chicago for test and demonstration
purposes. Ammeter readings showed that the machine was operating
at between 75-80 horsepower, although it was previously thought
by Griffith that a 35 horsepower motor would be adequate.
Turner 154, 156-160; Griffith 529; R. 674.
48. During the American Meat Institute convention that was held
in Chicago in September of 1956, Griffith displayed the "Mince
Master" emulsifier and demonstrated this sealed machine at
49. A "Cutfix" meat emulsifier of Robert Friess K.G. (hereafter
referred to as "Friess"), of Germany, was shown for the first
time in this country at that convention. It was a copy of a
Griffith 526, 527; DX-271F, page 432; PX-65; PX-67; PX-80.
50. Allbright-Nell, a manufacturer of equipment used by the
meat industry, saw the "Mince Master" emulsifier during the
American Meat Institute convention in the Fall of 1956.
51. About September, 1956, Mr. Carroll L. Griffith, president
of Griffith, received a telephone call from Mr. Norman Allbright,
president of Allbright-Nell. Mr. Allbright asked if it were
possible for Allbright-Nell to enter into an arrangement whereby
Schnell's "Mince Master" machine might be built in the
Allbright-Nell plant. Mr. Griffith explained that this was not
possible because Griffith Laboratories was Schnell's U.S. agent
and that Schnell had manufacturing facilities in Germany and
wanted to build the emulsifiers there.
Griffith 529, 530; R. 565.
52. Allbright-Nell sought and obtained from Friess a "Cutfix"
meat comminuting emulsifier in January of 1957. This machine was
a copy of a Schnell emulsifier.
DX-271F, page 432; R. 190, 566, 674, 675; PX-65; PX-67; PX-78;
PX-80; Photograph A of PX-17.
53. In January of 1957, Allbright-Nell started to duplicate the
"Cutfix" machine. Allbright-Nell made castings from it and built
an Americanized version (PX-68, Photograph B of PX-17) from these
R. 190, 191, 567, 573, 591, 675; PX-65; PX-67; PX-68; Photograph
B of PX-17.
54. In describing this copying, Mr. Ralph W. Illsley, chief
engineer for Allbright-Nell, testified on page 19 of his
"A. * * * We found that the German fabrication was
a problem for the maintenance people and we elected
to construct a machine on American standards with
American bolts and nuts and screws and things of that
kind which a mechanic would replace in the field. The
Germans came in with all metric system parts
which were absolutely not interchangeable.
"Q. You say, `We decided this.' Was that decision
one that you made or did somebody else participate in
"A. It was our management group.
"Q. Who was the management group at that time?
"A. Mr. Allbright, Mr. Norman Allbright, Mr. John
55. On page 20 of his deposition, Mr. Illsley added:
"Q. Now after this decision to rebuild on American
standards was made, did you rebuild?
"A. Yes. We took the German machine, part for part,
and made new parts similar, but to American
standards, and installed them. We also found the
German motors to be troublesome and we installed new
56. Mr. Carroll L. Griffith warned Mr. Norman Allbright that
Griffith Laboratories and Schnell expected to be granted patents
in the U.S. and that Schnell was defending his European patents
and would likewise defend his U.S. patents. This was confirmed by
Mr. Griffith's letter of March 22, 1957.
Griffith 532, 533; PX-40.
57. Representatives of Friess told Allbright-Nell in February
of 1957 that Friess wanted Allbright-Nell to be the U.S. "Cutfix"
representative. In May of 1957, Mr. Allbright told Friess that in
the light of Schnell's patent position, Allbright-Nell would not
enter into an agreement with Friess, but said nothing about
Allbright-Nell's copying of the "Cutfix" machine.
58. During May of 1957, Eckrich, a sausage manufacturer, and
Allbright-Nell orally agreed to cooperate in constructing and
testing an emulsifier for meat.
59. On June 13, 1957, an Americanized "Cutfix" machine having a
larger hopper and larger American motor was sent by
Allbright-Nell to Eckrich. This machine was a copy of a Schnell
R. 191, 676; PX-68; Photograph B of PX-17.
60. Mr. Nicholas H. Nusbaum of Eckrich said that after seeing
the "Mince Master" machine at Saratoga, he liked it and thought
that the Americanized version was "almost identical" to the
"Mince Master" machine, however, "built to American standards."
This view was shared by others at Eckrich and is readily evident
upon comparison of the machines.
R. 613; PX-41; PX-73; PX-103.
61. During the Fall of 1957 and thereafter, defendants agreed
and conspired together:
(a) To modify further the Americanized "Cutfix" machine (PX-68,
Photograph B of PX-17) and have the modified machine operate
like the "Mince Master" emulsifier that was displayed by
Griffith during the American Meat Institute convention in
September of 1956;
(b) To procure from Griffith a "Mince Master" emulsifier made by
Schnell and sold in the U.S. by Griffith;
(c) To carry out tests with a "Mince Master" emulsifier at
(d) To use the "Mince Master" emulsifier and spare parts for
testing and providing a standard for copying purposes and for
comparing and finalizing their copies; and,
(a) R. 613, 614, 622, 624, 628-34, 636-41, 649, 650;
PX-43; PX-44; PX-48; PX-52A; PX-52B; PX-53; PX-92A
and C-R; PX-94A-H; PX-99; PX-100; PX-101; PX-104;
PX-105; PX-107; PX-108; PX-109; PX-110; PX-112;
(b) R. 631, 632, 637, 639; PX-97; PX-98; PX-102;
PX-103; PX-104; PX-107; PX-111.
(c) R. 615, 631, 641, 642; Sondej 3291, 3320; Schmidt
(d) R. 641-43, 645-50; Sondej 3287-89, 3291, 3320;
Schmidt 3514-15, 3528-29; PX-49; PX-50; PX-51A;
PX-51B; PX-53; PX-92A and C-R; PX-94A-H; PX-115;
(e) R. 616, 637, 645, 659-62; PX-41; PX-45; PX-47;
62. During this period, Allbright-Nell was given free access to
emulsifiers and parts being built or tested at or by Eckrich.
Plaintiffs had no such free access.
Sondej 3247, 3287-3291; Schmidt 3511, 3512; R. 616-617; DX-174;
63. The oral agreement of May, 1957 between Allbright-Nell and
Eckrich was in effect until March 10, 1959, at which time Eckrich
and Allbright-Nell entered into a written agreement. The written
agreement confirmed previous oral agreements for cooperation in
the construction and testing of emulsifiers. Allbright-Nell also
agreed to defend Eckrich against patent infringement suits by
plaintiffs, or either of them.
R. 662-665, 676, 677; PX-54.
64. On September 21, 1957, during the American Meat Institute
convention at the Palmer House Hotel in Chicago, Mr. Norman
Allbright and Mr. Ralph W. Illsley of Allbright-Nell and Mr.
Chester W. Schmidt and Mr. Henry Eckrich of Eckrich, met at the
Palmer House and, at that time, planned to place an Americanized
"Cutfix" machine on its side or in a horizontal position.
65. Eckrich ordered from Griffith a sealed "Mince Master"
machine during the Summer of 1957 and received one on November
15, 1957. It was demonstrated at Eckrich during December of 1957.
It revolutionized Eckrich's processing procedure. It enabled
Eckrich to produce more and better meat emulsions than it ever
obtained before. This "Mince Master" machine has been used
extensively by Eckrich to emulsify for sale many hundreds of
thousands of pounds of meat material, and was used by Eckrich as
a standard for Allbright-Nell's and/or Eckrich's copies of the
"Mince Master" machine.
R. 621, 622, 631, 632, 637, 639; Schmidt 3523-3529; Sondej
3287-3291; PX-10; PX-92A and C-R; PX-94A-H; PX-97; PX-98;
PX-102; PX-103; PX-104; PX-107.
66. Eckrich made a horizontal emulsifier for making sausage
during October-November of 1957 and it was tested by Eckrich
during December of 1957.
R. 676, 677; Sondej 3278.
67. Eckrich received a second sealed "Mince Master" emulsifier
from Griffith in April of 1958. This machine was designated by
Eckrich as a stand-by machine for the first "Mince Master"
machine to assure Eckrich that it would always have ...