(Case that developed chain-of-commerce argument)(Court upheld injunction against price-fixing by meat-packers)

i.  Activity can be regulated under commerce power not because it had an effect on commercie – but rather – because the activity itself could be viewed as being part of a “current” of commerce.

ii.  Holmes-When cattle are sent for sale from a place in one State w/ expectation that they will end up in another and when this is a continuing business – this is part of commerce.

iii.  In Stafford (1908), Court says that the Court should defer to Congress as to connection between local acts and interstate commerce.