In May of 1913, Comstock threatened a New York art dealer with arrest after the dealer exhibited the painting “September Morn” by Paul Chabas at his gallery. The arrest never took place, but within a few weeks, thousands of lithographic reproductions of “September Morn” were on sale across the United States.
Not to be deterred, the next year Comstock and two assistants raided two postcard shops, arrested two men and seized 185 postcards depicting a variation of “September Morn.” And in September of 1914, Comstock had Lewis Levy of the Prudential Art Company arrested for selling a “September Morn” pennant in which a man holds the maiden at gunpoint and shouts, “Hands up!” Comstock said the accused had “flooded the city with pennants,” and that his own representative, Charles J. Bamberger, had purchased two dozen. Mr. Levy paid a fine of $50.