In Far East Conference v. United States, 342 U.S. 570, 72 S. Ct. 492, 96 L. Ed. 576 (1952), the U.S. Department of Justice sought to enjoin alleged violations of the Sherman Anti-Trust Act. Id. at 573. The Far East Conference, a voluntary association of steamship companies, operated under an agreement that had been approved by a federal administrative board established to oversee international shipping under the Shipping Act. Id. at 572. Although the agreement, which authorized a dual system of rates, was approved by the administrative board, the specific rates had not been directly submitted to the board. Id. at n.4. The defendants moved for the dismissal of the action, noting that the government had not first filed a complaint with the board although it was entitled to do so. Id. The district court refused to defer the action to the board, relying on its jurisdiction to decide the matter under the anti-trust act. Id. at 571 n.1. The United States Supreme Court reversed, citing its previous decisions that detailed the purpose, scope, and limits of the Shipping Act. Id. at 573-74.