It is an amazing and a sobering thought that by the utterance of a single ill-considered word a man may today commit forty-nine separate torts, for each of which he may be severally liable, in as many jurisdictions within the continental limits of the United States alone, and without regard to any additional liability he may incur in the possessions and territories and in foreign countries. It calls to mind at once in all solemnity those first words that ever were sent over an interstate wire, and later to the moon. What, indeed, hath God wrought!

Little less astonishing, although on a definitely lower plane, is the state of the law which man hath wrought. It is the purpose of this paper to consider the complex and confusing problem of tort liability for interstate publication, and to inquire whether there is a solution, and whether we may not be driven to find one. As a background for what follows, let us begin by stating a case.