696 HARVARD LAW REVIEW In 187 1 Congress granted a charter to the Centennial Board of Finance for the national exposition of 1876. In 1889, for the purpose of regulating commerce with foreign countries and among the states, Congress incorporated the Mari- time Canal Company of Nicaragua as a private stock company for profit with authority to construct a canal in foreign territory, and in 1890 the North River Bridge Company was incorporated by Congress with power to build a bridge over the Hudson River between New York and New Jersey, to exercise the right of eminent domain and to sue and be sued in the United States Circuit Court.^^ The Supreme Court likened the creation of this corporation to the creation of "a bank for the purpose of carrying on the fiscal operations of the United States, or a raihoad corporation for the purpose of promoting commerce among the States." ^^ The Wheeling Bridge Case,^ related to the paramount control of Congress over a bridge erected by a state corporation, and in Stockton V. Baltimore 6* New York Railway Co. the authority to construct the bridge had been given by Congress to corporations of New York and New Jersey. The American Red Cross Society, incorporated in the District of Columbia in 1881 and 1893, was finally reincorporated by act of Congress under government supervision in 1905. The Panama Canal was built by the government. The United States Shipping Board is a commission and its Emergency Fleet Corporations are organized under the laws of the District of Columbia.^^ The Federal Reserve Banks are made up of national banks.^ Hitherto Congress has confined the exercise of its power to create corporations pretty strictly to the organization and regulation of national banks and of transcontinental railroads. It has not attempted to require the federal incorporation of existing railroad companies chartered by the states, even though their business within the state of their origin is insignificant, nor has it attempted to insist upon federal incorporation of companies organized for commercial business coextensive with the whole country, still less to incorporate manufacturing companies even though they exercise " 26 Stat, at L. 268. ^ Luxton V. North River Bridge Co., 153 U. S. 525, 529 (1894). » 18 How. (U. S.) 421 (1855).
- 38 Stat, at L. 251, December 23, 1913.
^* 39 Stat, .at L. 227, June, 1916.
