In a test of more than 100 so-called contraceptives undertaken by the Birth Control Clinic Research Bureau, New York, forty-five were discovered to be unreliable. Today the marketing of devices, drugs and technics for the prevention of conception is in the realm of big business. Indeed, the marketing of books on the subject has also come to be an exceedingly profitable venture.
In a recent consideration of birth control as a business, Elizabeth H. Garrett1 credits the tremendous recent expansion to a court decision which affirmed that sales of materials for birth control were legal unless the seller was in complicity with drugstores to resell illegally. The court also said: "The intention to prevent a proper medical use of drugs or other articles merely because they are capable of illegal uses is not lightly to be ascribed to Congress." The decision was handed down in 1930. Immediately the country