Response or Comment
From the time of the introduction of the sleeping car there has been a constant feud between the sleeping car companies and the travelling public in regard to the upper berths. The exigencies of the situation have, of course, made economy of space a prime requisite in sleeping car construction, and there is no doubt but that a high degree of success in this respect has attended the efforts of the sleeping car builders.
Sunderland, Edson R. "Police Regulation of Sleeping Car Berths." Mich. L. Rev. 6 (1908): 403-4.