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his sight, through Jesus Christ, to whom be glory forever and ever, is the hearty prayer of "Your honor's most miserable and afflicted servant, Stede Bonnet." Shortly expedition search of capturing

after Bonnet's sentence a second sent by Governor Johnson in the pirates was also successful, a large crew of them, twenty-

three of whom were executed November 24. This, together with the efforts made by Governor Spotswood of Virginia, who slew both the noted pirates Black Beard and Worley, taking captive their crews, completely broke up the nest of pirates on the Carolina coast, and thereafter gave peace to the troubled waters of commerce.

FOREIGN COMPANIES IN FRANCE. IT seems well that legal and commercial circles in America should have their at tention directed to a recent decision of the Court of Cassation which reveals an unsatis factory attitude on the part of the French legal tribunals towards foreign companies carrying on business within the territory of the Republic. The decision in question was given under the Anglo-French Convention of 1862. By this convention the high con tracting parties " declare that they mutually grant to all companies and other associations, commercial, industrial or financial, consti tuted and authorized in conformity with the law in force in either of the two countries, the power of exercising all their rights, and of appearing before the tribunals, whether for the purpose of bringing an action or for de fending the same throughout the dominions and possessions of the other power, subject to the sole condition of conforming to the laws of such dominions and possessions." The obvious meaning of this treaty is that,1 ( 1 ) companies constituted according to British law, are British companies; while those con stituted according to French law, are French companies : (2) all British companies are en titled to exercise all their rights and bring or defend actions in France or viee versa. "In other words," to quote Mr. Barclay ( ubi 1Cf. Mr. Thomas Barclay's "Companies in France" (Sweet & Maxwell, London, 1899). A brilliant and ex haustive monograph on this branch of the law.

infra at p. 14), "a duly constituted British joint-stock company is, under the convention, a corporate entity, and when it brings or de fends an action in a court of law, it presents itself as a legal person complete and indi visible. The only condition imposed by the convention is that, having been properly con stituted in Great Britain, the company shall conform to the laws of F ranee, that is to say, shall do nothing which a French company would not be permitted by law to do." In .the case of La Construetion, Limited, however, the Court of Cassation adopted a very different interpretation of the conven tion, and as England's lot to-day may be America's to-morrow, it may be interesting to examine the facts in some little detail. La Construetion, Limited, had been reg istered as a British limited company in May, 1 888. The subscribers of the memorandum of association and the first directors had been British subjects exclusively. In 1890, three Frenchmen were elected directors in the place of three retiring Englishmen, and it was at the same time decided in general meeting that thenceforward the board meet ings might be held in France. The company bought land and erected a casino with money advanced by one of the new French directors. He was repaid in February, 1894, by the al lotment of a certain number of fully-paid shares to his nominees. Debentures at or about this time were issued on a morttracre