According to the census of 1910 about 4,000 women are employed in the factories in Texas. Textiles are not separately listed, but it is fair to surmise that a small minority of the 4,000 women are garment workers covered by the new law, and that the great majority are employed in the cotton mills, without any legal limitation of hours. Besides garment workers, the new law includes women employed in any “printing office, dressmaking or millinery establishment, hotel, restaurant or theater, telegraph or telephone office.” Laundry owners are allowed to employ women eleven hours in twenty-four, provided that “time and a half” is paid for work done in excess of ten hours. A comment by the Texas commissioner of labor on the new law is worth quoting: “Will not attempt to apologize for the same,” he writes, “but will admit it is not much.” In New York a new law has been enacted which is of national as well as state importance. This measure was unanimously recommended by the New York State Factory Investigating Commission after careful investigation. It prohibits the employment of women at night in manufacture, between 10 P. M. and 6 A. M. It brings the Empire State with its 300,000 women employed in manufacture up to the level of the fourteen civilized nations of Europe which have by international treaty abolished the night work of women in factories. Hitherto only three states, Massachusetts, Indiana and Nebraska, have enacted in their statutes the principle of assuring to working women a fixed period of rest at night—a principle adopted by England as long ago as 1847 in the first factory legislation. In this country, usage has so blunted our perception of the effects of work carried on to midnight or all night, that the establishment of a legal closing hour is one of the last steps taken even by progressive states. Yet in Massachusetts 10 P. M. has been the legal closing hour in factories for almost twenty-five years, and the great textile trade has flourished with an even earlier closing hour for women, set by law at 6 P. M. since 1907. In recommending the enactment of the nightwork bill, the Factory Investigating Commission carefully considered the adverse opinion of the New York Court of Appeals, which five years ago, in the Williams case, declared unconstitutional a similar law prohibiting the night work of women. The commission concluded that two new circumstances justified the enactment of a new law and the reargument of the principle at stake before the highest court of New York—the only court of last resort which has rendered a decision on this subject.