The issue of filled milk came to the forefront in United States v. Carolene Products Co. wherein Carolene Products Co. was indicted in the United States District Court for the Southern District of Illinois for violation of the Act by the shipment in interstate commerce of certain packages of "Milnut," a compound of condensed skimmed milk and coconut oil made in imitation or semblance of condensed milk or cream.
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Even the United States District Court for the Southern District of Illinois that originally ruled that a rational basis supported the Filled Milk Act reversed their decision in Milnot Co. v. Richardson, 350 F.Supp.
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Coconut oil could be cheaply imported, primarily from the Philippines (at the time under American rule), and this product was able to undercut the market for evaporated and condensed milk.
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