 According to freelancer Isabel Wolff, William Steinway would admit in his diary that under his leadership the New York City arm of the company bribed judges at trade fairs to favor Steinway pianos.According to musicologist Donald W. Fostle, it is untrue that Steinway repeatedly bribed judges at trade fairs, and in the one documented case it is unclear if Steinway were enmeshed, along with others, in bribery or were the target of attempted extortion.To reach European customers who wanted Steinway pianos, and to avoid high European import taxes, William Steinway and C. F. Theodore Steinway established a new piano factory in the free German city of Hamburg in 1880.