law. Section 3 simply extends the provisions of Section 1 to U.S. territories and the District of Columbia. Subsequent legislation expanding its scope The Clayton Antitrust Act, passed in 1914, proscribes certain additional activities that had been discovered to fall outside the scope of the Sherman Antitrust Act. For example, the Clayton Act added certain practices to the list of impermissible activities: price discrimination between different purchasers, if such discrimination tends to create a monopoly exclusive dealing agreements tying arrangements mergers and acquisitions that substantially reduce market competition. The Robinson–Patman Act of 1936 amended the Clayton Act. The amendment proscribed certain anti-competitive practices in which manufacturers engaged in price discrimination against equally-situated distributors. Legacy The federal government began filing cases under the Sherman Antitrust Act in 1890. Some cases were successful and others were not; many took several years to decide, including appeals. Notable cases filed under the act include: United States v. Workingmen's Amalgamated Council of New Orleans (1893), which was the first to hold that the law applied to labor unions. Chesapeake & Ohio Fuel Co. v. United States (1902), in which the trust was dissolved Northern Securities Co. v. United States (1904), which reached the Supreme Court, dissolved the company and set many precedents for interpretation. Hale v. Henkel (1906) also reached the Supreme Court. Precedent was set for the production of documents by an officer of a company, and the self-incrimination of the officer in his or her testimony to the grand jury. Hale was an officer of the American Tobacco Co. Standard Oil Co. of New Jersey v. United States (1911), which broke up the company based on geography, and contributed to the Panic of 1910–11. United States v. American Tobacco Co. (1911), which split the company into four. United States v. General Electric Co (1911), where GE was judged to have violated the Sherman Anti-Trust Act, along with International General Electric, Philips, Sylvania, Tungsol, and Consolidated and Chicago Miniature. Corning and Westinghouse made consent decrees. United States v. Motion Picture Patents Co. (1917), which ruled that the company was abusing its monopolic rights, and therefore, violated the Sherman act. Federal Baseball Club v. National League (1922) in which the Supreme Court ruled that Major League Baseball was not interstate commerce and was not subject to the antitrust law. United States v. National City Lines (1953), related to the General Motors streetcar conspiracy. United States