Oregon Exchanges/Volume 5/Number 2

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Oregon Exchanges, Volume 5 (1922)
Number 2
2586640Oregon Exchanges, Volume 5 — Number 21922

Oregon Exchanges

For the Newspaper Men of the State of Oregon



Vol. 5
Eugene, Oregon, February, 1922
No. 2



SOME DEVELOPMENTS IN ADVERTISING IN THE LAST YEAR

By G. LANSING HURD, Manager, Corvallis Gazette-Times


[Mr. Hurd made the following address at the recent annual Oregon Newspaper Conference. Most of the advertising developments of the year Mr. Hurd regards as favorable.]

I ASKED some newspapermen about the developments in advertising in Oregon during the last year, and I got very few satisfactory answers. There have been some very substantial and altogether satisfactory developments, both to the publisher and to the advertiser.

For the first of the developments that I would mention here, I choose an improvement in the efficiency of copy-writing. There has been a distinct improvement in the character, quality and effectiveness of the copy of the advertising in both the weeklies and the dailies, and that increase has been larger than the increase in the extent of space sold to the customer.

There also has been a well-defined policy in some places—in Corvallis and Albany, that I am more familiar with and, I have been told, in Salem and Eugene, on the part of the merchants to substitute newspaper advertising for the use of posters, hand bills, catalogues, and things of that sort.



vertising cut service, and also the appli cation of more particular care in the dis play, make-up, and arrangement of the advertising. There have been some increases in rates to the local advertisers; there have

been some increases in rates to foreign


advertisers. But so far as I have been able to learn, the increases in rates to


have been more numerous and more sub


than the increases in rates for foreign


Tvrooaarnr Now Barren

The third improvement is the develop ment made in the typography of adver tising. The advertising in Oregon news papers this last year has unquestionably been distinctly improved through the adoption of the mat service and the ad

local advertisers during the past year stantial.

And they are more important

advertising.

CIRCULATION GAIN Snown Circulations, according to information contained in the Standard Rate and Ad vertising Data Service, have held their own or increased. According to those data no daily newspaper of Oregon has lost materially in circulation, while several have made substantial gains. Some con solidations have brought about very con siderable circulation gains. . . . I think there has been a general de velopment of a better understanding and

an appreciation of the value and possi bilities of local newspaper advertising on the part of very many of the national manufacturers. During the war, when advertising was done by many firms largely to avoid the payment of the excess profits taxes to the government, there developed an immense amount of national advertising. most of which was done in

the Saturday Evening Post and other magazines first, the remainder being appropriated for newspaper advertising in a haphazard sort of way. Large advertising agencies contributed to the popularity of this style of advertising because it was more profitable for them to handle these large accounts in this manner than to go to the trouble of advertising in newspapers.

Even our own state contributed many thousands of dollars during that time to national advertising, the Oregon Woolen Mills and several others being among the leading national advertisers.

Now that war-time conditions no longer prevail, advertising is being considered again from fundamental economic stand points, and quality, effectiveness, and results are carefully considered. The result has been in favor of the use of local newspapers rather than magazines, and study of the trade papers indicates that this present attitude of the national advertisers to regard newspapers with more favor than the national magazines is rapidly becoming general.

Since the noon hour I have talked with half a dozen of the daily publishers, and they tell me that there is more national adr:crIi-i;z-r] c 0 m ing than last year, and the trade papers

advertising of one local insurance firm whose excellent copy was prepared by an old company in Connecticut, and offered the Corvallis firm only with the under standing that it would be printed on a regular schedule. This company thought enough of local advertising that, although the copy was not devoted to their insurance, they signed up for one year. Of

fers of copy, together with cuts, are being made to the local merchants more generously than ever before. The J. C. Penney Company during the last year has adopt

ed a policy of more vigorous advertising in the local or-wsp:rpcr.<. and now offers the local managers complete copy suggestions instead of ideas, layouts, specimens, and on frequent occasions, with actual ordcis issued from New York to use more elaborate advertising in the local news

papers.

This firm has carried a number

of page ads since last summer.

llAILED Posrun IN DISCARD

'e recently interviewed local merchants, then went to Albany to talk with the merchants there about their advertising, and found the same conditions to exist there. Leading merchants at both

places assured me that the same is true at Eugene and at Salem. Leading merchants stated that the practice of issuing posters to be distributed by mail or through agencies has been discarded in favor of larg1cr newspaper space, supplemented by a limited quantity of posters.

indicate that there will be a great deal more national advertising d u r 1' n y 1922 than was printed in 1921.

And whichever they have something special to put across. they eliminate competition from other advertisers on the page

by taking not only the entire page, but a

llANUFAC'I'URl~lRS PAY SHARE

You have doubtless come in contact with the offer of certain manufacturers, who now olfer to the dealers to bear half, or a larger proportion, of the cost of advertising their clothing in the local news papers. Farm implement manufacturers are now sending out copy suggestions and specimen ads for the use of their

local dealers in the local newspapers, with the urge that they make better use of the possibilities. We are carrying the

double page in the center of the paper.

In Portland this fall there seems to be a tendency to use two entire pages in separate parts of the paper rather than the two-page spread. 1 do not know exactly what that means. I call attention to that because I am studying that—why

Meier & Frank have seemingly abandoned that double-page spread.

If you can

give me any information on that point I would appreciate it.

r2]

(Continued on page 23)

SOME NEGLECTED OPPORTUNITIES IN JOURNALISM

BY GEORGE P. CHENEY, Editor, Enterprise Record Chieftain

[One of the features of the banquet on the occasion of the Fourth Annual Newspaper Conference was Mr. Cheney's address on some of the v'.'-"l{’r('$§0S of ioirrunlism as he had olrservrd them. His charges of Prejudice and policy-colored news drew a reply from Edgar B. Piper, editor of the Oregonian, who expressed entire confidence in the fairness of the newspapers and the freedom of their news columns from h':.<. The two speakers verc thorouwhly agreed on the v:~.lu-a of jnur|i:.li-rtic rthi"s but difiered as to how far along the road toward perfection in this respect the newspapers have already gone. ]

I HAVE nothing constructive to offer. I have no inspirational message. It subaltern, a domestic advocate unceasingly suborned, employed by the proprietors to plead in their behalf.” Let no one be surprised, therefore, if

is my part to attempt an analysis or criticism of certain customs, practices

prejudice persists in the editor and news

and habits of thought found in news paper work.

Let us stand before a mirror and look at ourselves. And instead of admiring the massive dome of intellect of the composite head reflected in the glass, let us see if we cannot detect a bump of egotism. Instead of the keen and pierc

writer. Up to a decade ago prejudice formed the chief reason for the existence

of most periodicals.

it had to have such an organ and advocate wherever it sought to grow. In more recent years another conception

ing eye, perhaps we will note defective and jaundiced vision.

of the field of a newspaper has been ac

First I will speak of the city news

cepted.

papers and their writers, and I will note bundles of passions, whime. desires,

prejudices, which are the master, the guiding motives of action. IVc talk of being impartial and unbiased, and perhaps we honestly try to attain to that sublime state.

Every newspaper

was the organ and advocate of some party or faction, and every party or faction felt

The so-called independent news

paper is the consequence, and it professes to print all news, of all parties and factions, with unbiased impartiality. In this it succeeds only indifferently. In the year of a presidential election partisan feeling runs high. In such a year, not a single daily paper in the city

of—say, Boston—prints the truth, the

PREJUDICE STILL PERSISTS

pure and unadorned truth, in its politi

At several times in history man has fancied he has freed himself from the rule of the passions and has enthroned reason.

cal columns.

Misrepresentation, exaggeration and garbling of facts are practiced

without exception.

Such was the philosophy of the

Between campaigns, partisanship takes

leaders of thought of the period preceding the French Revolution, but in the fol lowing century the writer, Taine, pointed out their error, saying: “ Not only is reason not natural to

a half vacation, but it does not leave the

man

nor

universal

in

field wholly. Prejudice finds expression chiefly through the medium of special cor

respondents, and particularly the Washington

correspondents.

We

note

two

humanity, but,

classes of correspondents, those who seek

again, in the conduct of man and of humanity, its influence is small. The place

to supplement the regular news agencies and those who parallel those agencies.

obtained by reason is always restricted, the ofiice it fills is generally secondary.

the press bureaus have an admitted news

Openly or secretly, it is only a convenient

value.

Correspondents who seek to supplement

[3]

They dig up odd and out-of-the way stories which do not come in the run of general news, or they furnish stories of peculiar value to the paper served but

the facts. He went through the camp and saw everything. There were no luxuries and there was discomfort, but, as the rep resentative said:

“ I was raised in the west and on my hunting and camping trips I voluntarily sulfered far greater hardships, much more

not of such general value as to warrant their being carried in the regular agency reports.

BIAS IS REQUIUI

exposure, than I found at Camp Mills.”

Correspondents who parallel the bureaus are engaged in the interest of prejudice and propaganda.

On his return to Washington the congressman was interviewed by a correspondent who regularly served the leading newspaper of the western state interested,

I know many editors will deny this and say the correspondents furnish better written stories and give the paper individuality and variety.

and also was interviewed by another cor respondent, one of those unfortunate fel

In some cases this is true, but I insist that the most common purpose of the correspondents is to provide stories with the

lows who hunt in the twilight zone of the news field and call themselves free lances.

bias or prejudice of the employing paper. A year or two ago, important conferences were on at Washington. A daily

FEARFUL SUFFERING Tom)

A few days later the representative re ceived his paper from home and what was

paper which I read with much pleasure

his astonishment and mortification to read,

carried each day two stories of the developments. On the inside, on page 3, 4, or

prominently displayed, an interview from him in which he told of the fearful suffering. the neglect and barbarous treatment of soldiers he had seen at the camp.

5, was the news agency story, replete with detail, efiectively arranged and a master of newspaper composition. It was as free

The representative went at once to the

from prejudice as humanly possible and anybody could read it and get a compre

regular correspondent and demanded to

hensive view of the events described.. But, meanwhile, on the first page of the

see the story he had filed west the night of the interview. It was shown him and proved to be a sane and truthful report of the talk. Then the congressman real

paper appeared daily, a story from a special correspondent, who sought to inter pret the events, to read into them the

meaning he wished to give. The agency story was news; the special correspon

ized what had happened. Two stories had reached the western pa

propaganda, nothing

per that day; one from the regular cor respondent and one from the free lance.

ONE Ixsmscn Crrsn

In the fall of 1920 I had a long visit

The editor had thrown away the regular correspondent’s story, which he had every reason to believe was the truth, and had

dent’s else.

story

was

with a western congressman. You will remember the harrowing tales told of con ditions at Camp Mills, on -Long Island, in the early stages of America’s participation in the world war. It was said the

soldiers were not properly housed or clothed, that they sufiered from cold, from exposure to rain and snow and were insufiiciently fed. The nation was shock

ed by the tales of sulfering and neglect. Many western boys were at the camp,

and the congressman said he went there, in the interest of his constituents, to learn

printed the coyote’s story, which he had every reason to believe was a lie. It was more sensational and suited the prejudice of that editor.

Second, I will speak of superficiality in news writing. The editor and the re porter handle an almost infinite variety of stories in the course of a year. The reporter is in‘signed to a fire one day, to

a political meeting the next, then to a flood, a street accident, a scientific discovery by a physician, an investigation

[4]

(Continued on page 18)

SOME WEAKNESSES IN THE NEWSPAPER LAW OF OREGON

By WILLIAM G. HALE, Dean of School of Law, University of Oregon


[Dean Hale read this paper at the Fourth Annual Oregon Newspaper Conference, in his capacity of special adviser to the committee on codification of the Oregon laws dealing with the press. Dean Hale expressed the opinion that present conditions do not call for an immediate attempt at codification of the Oregon newspaper laws, but that some few statutes dealing with the papers appear to require amendment.]

A YEAR ago it was my privilege to report to this Conference on some of the more important features of the law of libel. Since then, at the request of your Committee on Codification, which consists of Eric W. Allen, dean of the School of Journalism of the University of Oregon; Robert W. Sawyer, editor of the Bend Bulletin; E. A. Koen, editor of the Dallas Observer; E. E. Brodie, editor of the Oregon City Enterprise; E. B. Aldrich, editor of the Pendleton East Oregonian, and Edgar McDaniel, editor of the North Bend Harbor, I have made a further study of the law in Oregon and other jurisdictions, both common and statutory, with a view of determining whether an attempt at codification is necessary and expedient. This study, combined with a more mature consideration of the whole question of codification, has led me to the conclusion that such a step is not called for by present exigencies and in addition is for the present open to some objections on grounds of policy.

My investigation reveals, first, that the law of libel has not proved especially burdensome to the newspapers of this state. In the entire history of the state only six cases against newspapers have reached the Supreme Court and in all of them the rules announced are free from ambiguity and are in accord with those laid down by a large majority of the courts in other jurisdictions. It is true that some of the rules are not as favorable to the newspapers as they might wish. In Upton v. Hume (24 Or. 420), for example, it is held that misstatements of defamatory facts concerning candidates for office are not qualifiedly privileged and hence that proof of the truth of the charges constitutes the only legal justification. This doctrine is open to question on principle and is not approved by all courts.[1] It is however in accord with the great weight of authority elsewhere, has much sound argument back of it and would most certainly receive full support by members of the legislature and other men in political life. Any attempt to change it, therefore, would probably be inexpedient.

It is also true that some questions over which other jurisdictions have been in dispute have not arisen for adjudication in Oregon. But on these questions likewise it is somewhat doubtful if rules could be formulated that would be at once acceptable to the newspapers and to the legislature and public.

Moreover, it is quite possible that, if issues were once raised in the form of a bill, the legislature would reverse the rules offered by the news paper proprietors, thus making their latter and worse, if anything, than the beginning.

Finally it may be pointed out that no program will succeed that appears to represent a mere self-seeking on the part of newspapers. Rules that are distinctly more favorable to journalists than those which now obtain in Oregon or are followed generally elsewhere can only be put through if they are part of an extensive program which recognizes in the fullest measure the sacred value of reputation and the fundamental duty of the press to safeguard it and which accordingly provides some restrictions not now in force legally or ethically. In considering this phase of the problem, cognizance should be taken of the fact that the practices, policies and ethical standards of the newspapers are undergoing marked changes. When these have crystallized in a new and higher form, then will be the propitious time for the formulation of laws that will gain for the press a freer hand.


SOME MISFIT STATUTES

In the meantime however there are a few Oregon statutes which, apart from the development of a large legislative program, may well receive your attention with a view to securing their amendment.

I may refer first to Section 2094, Oregon Laws, which prohibits the publication of articles that are indecent or obscene or that contain stories of bloodshed, lust or crime. In dealing with the latter topic the statute provides: "... if any person shall print, publish, advertise, sell, lend, give away, or show ... any book, paper, or other publication that purports to relate or narrate the criminal exploits of any desperate or convicted felon, or any book, paper or other publication that is principally devoted to, or contains, or is made up in part of accounts or stories of crime or lust or deeds of bloodshed . . . . such person shall, upon conviction thereof, be punished by imprisonment in the county jail not more than six months, or by a fine of not more than $500, or by both fine and imprisonment in the discretion of the Court.”

In so far as this statute condemns publications that are obscene, as it does in the part not here set out, or that are “principally devoted to . . . . stories of crime or lust or deeds of bloodshed,” it is an entirely orthodox piece of legislation and doubtless meets with the wholehearted approval of right-thinking journalists.

But it will be noted that the Oregon statute sweeps -much beyond those borders and brings under its ban any article no matter how short and no matter if it be the only one in the issue that narrates “the criminal exploits of any desperate or convicted felon” or that is made up “in part” of accounts or stories of bloodshed, lust or crime. The practice obviously does not conform to the law, Either the law or the practice should change.

Another statute that is entitled to your attention is contained in Section 4145, of Oregon Laws, which reads as follows:

“Electioneering on Election Day Prohibited. It shall be unlawful for any person at any place on the day of any election to ask, solicit, or in any manner try to induce or persuade any voter on such election day to vote for or refrain from voting for any candidate, or the candidates or ticket of any political party or organization, or any measure submitted to the people, and upon conviction thereof he shall be punished by fine of not less than $5 nor more than $100 for the first offense, and for the second and each subsequent offense occurring on the same or different election days, he shall be punished by fine as aforesaid, or by imprisonment in the county jail for not less than five nor more than thirty days, or by both such fine and imprisonment.”


{{c|Law's Purpose Praiseworthy

If this statute is given a literal interpretation it renders illegal the publication of practically any article or statement of a political character on election day. The truth of the utterances, their moderation, and the perfect good faith of the pub lisher are immaterial. Again the practice and the law do not conform. Which shall change?

In bringing these statutory matters to your attention I do not wish to have the inference drawn that I am not in sympathy with the purposes which lie back of them. Quite on the contrary, I most heartily endorse such purposes. Personally I should wish to see the press use much more moderation and discrimination in giving publicity to stories of bloodshed, lust and crime than it does. Many things, though true, are just as well not said and are not really news. The purpose then back of the first statute referred to is sound. The question is, Does it not go too far as a matter of law? The other statute is part of the corrupt practice act and is intended to purify elections. The section in question is doubtless aimed at the vicious practice that in former times was all too prevalent, of publishing in the newspapers or by hand bills, statements about men and measures that were unfair and untrue, at a time when they could not be answered, viz., on election day. In striking at that practice, which is admittedly evil, the statute has gone perhaps beyond the point that is necessary and has in fact condemned publications that are wholly commendable.


JOURNAL'S GREAT NEW OCTUPLE PRESS IS SILENT SPEED DEMON

Scores of Oregon Journal employes gathered in the press room shortly after noon on Friday, February 3, when H. A. King, veteran press room foreman, turned the electric current into the new and gigantic high-speed octuple press for its first regular run. The great machine, with more than 20,000 parts, set about like an old-timer at the task of printing the first afternoon edition of that day, and the occasion was strangely silent, for the big press, with the latest mechanical refinements, is apparently as nearly silent as mechanical ingenuity can make such a thing. Two years were required in building the big press, and two months of hard work were demanded for its installation on heavy concrete bases in the Journal press room. Nearby, when the press started its run, were Hyman Cohen, market editor, and Thomas J. James, composing room foreman, who have been Journal employes since the first issue was printed nearly 20 years ago. Felix Mitchell, another Journal veteran, was in the throng while a motion picture record of the event was made for Screenland News. The press has a capacity of 36,000 32-page papers an hour and 1800 64-page papers. It is the latest improved high speed machine of its type and is equipped with a color deck as well as with a conveyor that carries the papers from the press to the mailing department on the basement balcony. The capacity of the machine duplicates that of the Journal’s other high-speed octuple and both will be required to print the increasing volume of city editions every day. The other two presses, a sextuple and a quadruple, will be used to print other daily editions and sections of the Sunday Journal upon which color work is required. Thus the Journal’s maximum capacity becomes 208 pages, while the combined capacity of the six presses used by the other three Portland papers is 260 pages. On March 10, 1902, when the first Journal was printed, the press equipment consisted of one Goss 12-page capacity press.

A TWICE-A-WEEK AND BUSINESS

BY H. L. S'. CLAIR, Editor Gresham Outlook

[Mr. St. Clair made a distinct impression at the Fourth Annual Newspaper Conference with his Paper on the advantages of a twice-a-week for towns in which an weekly appears to be we slow. In answer to inquirig by Mr. Koen of Dallas, Mr. St. Clair explained that although, under an annchronism of the postal service a twice-a-week newspaper will not be delivered by mail within the city limits, he would hire a carrier and have the paper delivered to the people in the town, as they would appreciate the carrier service more than they would getting their papers through the mail. It costs a little more, but they appreciate it."]

WHETHER a semi-weekly newspaper is an advantage over a weekly depends principally on

them arc—is to be compared rather with the statesman, the educator or the author. Not seeking prefernient. or distinction,

three thin;_'s—the publisher, the field, the

or plaudits of men, he is fulfilling a high

equipment. Much depends upon the publisher—his

calling, working out an ideal, leaving the

ideals and breadth of vision. It requires a high conception of the objects and pur poses of a newspaper, a clear insight into

minds of old and young, often through

the needs and possibilities of a given locality, to establish a standard for a publication which will be creditable and

at the same time can be made to yield a profit. Back of every newspaper which is a

credit to the community in which it is published, is an editor who is devoted to his work. Combined in the same indi vidual or associated with him must be a publisher and business manager with his upper story full of business sense. It

takes 100 per cent business sense to make 100-cent dollars for the small news

paper. The publisher must be a genius, but not the kind you have heard of, who can see a dollar a long way off but is blind to a penny held before his eyes. Momz THAN A GAME You sometimes hear a publisher say

he is in the newspaper game.

impress of his clear thinking upon the out the life of a generation. Like the minister and the teacher, the editor carrivs on his work not merely for

the money, for he is often as poorly paid as either of the former. He has a larger audience than the minister and probably has more influence than the teacher in

building up loyalty and good citizenship among all classes. But the editor is usually also pub lisher and as such is a business man, and on the success of his newspaper in a business way depends the scope and permanency of his influence as an educator, a champion of right, an opposer of wrongs. There are more successful editors than there are publishers. If it were not so there would be more twice-a-week papers in the state. C0uno DRIVE WEEKLY OUT

The state

ment suggests a superficial view of one

Much depends upon the field a paper

of the most attractive and influential

is intended to cover.

professions of the day.

The attitude is

calities where a weekly, even, is too fast.

unworthy a successor of the long line of conscientious and high-minded men who have dignified the newspaper fraternity

The latest census report discloses in

in the past. . . . The newspaper man who is conscien

tious and a hard worker—and most of

[81

There may be lo

Oregon a surprising number of cities, they are classed as such, with a few dozen to a few hundred inhabitants, and some

of them are called upon to support a newspaper. There are other localities, some thriving county seat cities, that seem to be inviting fields for semi-weekly papers in place of the existing weeklies. I venture the assertion that if some enterprising fellow with a hatful of brains, good credit and fair equipment were to put a twice-a-week paper into competition with some of the Oregon weeklies the latter would be put out of business within twelve months.

Some weeklies were all right in their day—a day long past. The legend across their front pages ought to be, “Men may come and men may go, but we go on forever!”

I did not change from a weekly to a semi-weekly. Eleven years ago the Gresham Outlook was started as a twice

a-week paper. Three things caused Outlook twice a week. of the kind of service cality. The nearness

me to issue the It was my ideal needed in my lo of the big city

with its morning and evening papers dis tributed daily on rural routes covering a wide area made it necessary to speed up. There was already a well established weekly in the field. These were the reasons. The unexpected happened. Af ter six months of competition the weekly moved out. Goon Paorrr Snowx

Fnssn News Dmmnonn

Now for the practical side.

Does the

A newspaper is designed to give the

news while it is news.

A town that is

proverbially slow, has one show a week. one good trading day, depends on kero

sene lights. does most of its hauling by teams; whose patriarchal citizens sit on

semi-weekly pay? Is it a good business proposition? In presenting this phase of the subject reference will be made chiefly to my own observation, experience and records.

the rail fences and whittle and spit and

The Outlook has a subscription list at

discuss what happened in Franklin’s day,

present of 1100. The average for the year 1921 was 1050. Not over 50 of these are exchanges, ad or complimentary copies. The net subscription income for the calendar year just closed was $1355. The subscription price is $1.50 a year, strictly in advance. The paper is issued Tuesdays and Fri

may be well satisfied with a weekly. But a live city of a thousand or more, with a score or more of enterprising merchants,

centrally located in a fertile valley of Oregon, with a thriving farm population, in the country surrounding, where tele

phones, electric lights and automobiles are the common thing; where rural car

days, six columns, usually four pages.

riers deliver the mails daily, including daily papers; a community with the best of public and high schools, and where

A few times during the year six pages or even eight are required to accommodate

rural and civic, educational and religious activities and organizations abound—such a community he satisfied with a weekly

was 20 pages, 50 per cent advertising.

the advertising.

The recent holiday issue

Moon CLASSIFIED ADVERTISING

The advertising income for the year

newspaper?

Only out of pity for the 1921 was $7368, making a total income from subscriptions and advertising of

editor’s lack of ability to do better. A newspaper should be ahead of

its community life, not behind it. Personally I like a twice-a-week paper for a small city. A daily is

0 hard grind and impracticable ex cept in a city of five to ten thousand.

A sembweekly speeds up the news and advertising service somewhat in keeping with the spirit of the day.

$3623. Our records show an average of 60 per cent ads, at an average of 25 cents an inch. Our rate for foreign ads is 30 cents an inch. Local rates are 25 and 20 cents. Want ads and readers yield a higher return per inch. The Outlook carries an average of nearly two columns of classified ads, set solid 8 point, sepa

rated by thin rules.

[9]

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  1. See Coleman v. Maclennan, 78 Kansas 711, which holds that defamatory statements concerning a candidate for public office are qualifiedly privileged, and hence that the newspaper is legally exonerated if they were made in good faith. This case contains the best discussion available in support of this view. For the full presentation of the majority view see Starr Pub. Co. v. Donahue, (Delaware, 1904) 58 Atlantic Reporter, 513.