The first injunctions that attained wide publicity were those issued by Federal courts during the strike of engineers against the Chicago, Burlington, & Quincy Railroad[33] in 1888 and during the railway strikes of the early nineties. Justification for these injunctions was found in the provisions of the Interstate Commerce Act and the Sherman Anti-Trust Act. Often the State courts used these Federal cases as precedents, in disregard of the fact that there the issuance of injunctions was based upon special statutes. In other cases the more logical course was followed of justifying the issuance of injunctions upon grounds of equity. But most of the acts which the courts enjoined strikers from doing were already prohibited by the criminal laws. Hence organized labor objected that these injunctions violated the old principle that equity will not interfere to prevent crime. No such difficulties arose when the issuance of injunctions was justified as a measure for the protection of property. In the Debs case,[34] when the Supreme Court of the United States passed upon the issuance of injunctions in labor disputes, it had recourse to this theory. But the theory of protection to property also presented some difficulties. The problem was to establish the principle of irreparable injury to the complainant's property. This was a simple matter when the strikers were guilty of trespass, arson, or sabotage. Then they damaged the complainant's physical property and, since they were usually men against whom judgments are worthless, any injury they might do was irreparable. But these were exceptional cases. Usually injunctions were sought to prevent not violence, but strikes, picketing, or boycotting. What is threatened by strikes and picketing is not the employer's physical property, but the relations he has established as an employer of labor, summed up in his expectancy of retaining the services of old employes and of obtaining new ones. Boycotting, obviously, has no connection with acts of violence against physical property, but is designed merely to undermine the profitable relations which the employer had developed with his customers. These expectancies are advantages enjoyed by established businesses over new competitors and are usually transferable and have market value. For these reasons they are now recognized as property in the law of good-will and unfair competition for customers, having been first formulated about the middle of the nineteenth century.