The first and most important attempts by the US government to promote uniformity in commercial laws from state to state was by the grant of power to congress under Article 8, Section 1, Clause 3 of the U.S. Constitution which was introduced in 1797. This clause which is referred to as the The Commerce Clause gave power to congress to regulate commerce with foreign Nations, and among the several States, and with the Indian Tribes (U.S. House of Representatives 2004). A significant challenge came in 1824 in the case of Gibbon vs. Ogden where Chief Justice Marshall interpreted the Power of Congress to regulate commerce and in the same breadth prohibited states from interfering with the flow of goods and services across state boundaries by passing laws (Find Law n.d.). Chief Justice Marshall