Typed onto a piece of paper attached to the image: "Contemplative smile. Here, Howard Hughes seems in rapt thought during one of the numerous speeches extolling his feat. Probably thinking of the "men who designed and perfected to its present remarkable state of efficiency, the modern American flying machine and equipment." (The quote is from his own official statement to the press.) Credit Lines (ACME) 7/15/38."
Description printed on photograph's accompanying strip of paper: Attending the Advertising Club Luncheon in his honor, Howard Hughes is shown with (left to right) Eddie Rickenbacher, Frank Hawks, H. B. Lequattes, and Dick Merrill.