For purposes of Fed. Eq. R. 30, "transaction" is a word of flexible meaning. It may comprehend a series of many occurrences, depending not so much upon the immediateness of their connection as upon their logical relationship. That facts alleged in the counterclaim are not precisely identical to those of the subject matter of the suit, or that the counterclaim embraces additional allegations, does not matter. To hold otherwise would be to rob this branch of the rule of all serviceable meaning, since the facts relied upon by the plaintiff rarely, if ever, are, in all particulars, the same as those constituting the defendant's counterclaim.
Appellant cotton exchange filed an interlocutory injunction alleging that appellee cotton exchange violated their contract and the Sherman Act by refusing to sell continuous quotations to appellant. The court dismissed appellants request for injunction and instead granted appellee an interlocutory injunction on its counterclaim to prevent appellant from illegally obtaining the quotations.
Should the injunction be granted?
The U.S. Supreme Court affirmed the decree denying appellant cotton exchange an interlocutory injunction to force appellee cotton exchange to sell appellant continuous cotton quotations because appellee did not violate the Sherman Act, 15 U.S.C.S. §§ 1, 2, by entering into an agreement with another to provide quotations, as the contracts did not involve interstate commerce. The Court held that the contract did not affect interstate commerce because transactions between appellee and its members were purely local agreements for the purchase and sale of cotton futures and did not contemplate the shipment of cotton from one state to another. The fact that the agreements were likely to give rise to interstate shipments was insufficient to bring the quotation agreement within the ambit of the Act. The Court also affirmed the interlocutory injunction to appellee barring appellant from obtaining stock quotations without permission because appellee's counterclaim was properly asserted under Fed. Eq. R. 30 as it arose out of the "same transaction" that was the subject matter of the suit. The Court held that the term "transaction" encompassed separate, but logically related, occurrences.