Modern Plastic Machinery Corp. v. Frank W. Egan & Co.

How later courts describe this case

• holding that check-kiting scheme constituted mail fraud where worthless checks were passed between defendants' bank accounts in separate cities
• noting that an accounting is necessary to prevent unjust enrichment
• both the trademark owner and the buying public are slighted if the court provides no greater remedy than an injunction
• the court has wide discretion to require an accounting of profits for deliberate and willful trademark infringement