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175 Harvard Law Review. Published monthly, during the Academic Year, by Harvard Law Students. SUBSCRIPTION PRICE, $2.50 PER ANNUM 35 CENTS PER NUMBER Editorial Board. Robert G. Dodge, Editor-in-Chief. James A. Pirce, Treasurer. Franklin M. Archer, Robert L. Raymond, Roland Gray, Edward Sandford, Livingston Ham, Harry U. Sims, Logan Hay, Lloyd W. Smith, Harold D. Hazeltine, J. Lewis Stackpole, Jr. Robert Homans, Charles S. Thurston, William H. S. Kollmyer, Jens I. Westengard. On September 2d, 1896, Frederick B. Jacobs, A. B., 1889, LL. B. and A. M., 1892, died of consumption at his home at Norwell, Mass. While in the Law School he was an editor of this Review, and up to his death he held the position of Secretary of his Class. He was a man of marked ability, and possessed qualities that endeared him to all who knew him. At a meeting in Boston, September 19th, his Class adopted the following resolution : " We, the members of the Class of 1892 of the Harvard Law School, join in expressing our deep regret at the death of our classmate and friend, Frederick Boyden Jacobs. To those who knew him in college days he was an old and dear friend ; to his Law School class a kindly companion and a steadfast fellow student. His work proved him a scholar of high attainments ; his energy and capabilities gave promise of much success at the bar, and his strong personality showed above all the man. He had our respect and regard in his Hfe and our sorrow in his early death. We join in conveying to his family our sympathy for their loss, which is ours also." Philip Stanley Abbot, who was killed in mountain climbing on August 4th, was one of the most prominent members of the Law School Class of 1893. In the lecture rooms, in the Thayer Club, of which he was clerk, on this Review, of which he was editor-in-chief, he distinguished himself from the first by work which was at once brilliant and sound. He was an interested member of the Phi Delta Phi. The rapidity with which he worked and his unusual energy enabled him to do an unusual number of things and to do them all well. During his course at Har- vard College, from which he graduated near the head of his class in 1890, he had shown the same enthusiasm for thoroughness and variety of study and experience, doing equally effective work in his courses, in college journalism, and in philanthropic work. His interest in the theory