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 NOTES OF RECENT CASES nature of the business between the parties, the reason why these ' contangos ' or « continuations ' are often called loans is quite clear; but this does not alter the legal position of the parties concerned in them, or prevent the shares held by the brokers under such circumstances from being their own and available by them." In the present decision the Supreme Court is inclined to adopt the New York view, but at the the same time does not come out squarely to that effect. It recognizes there are many incidents in the relationship which are inconsistent .with that of a mere pledge. The Court reaches the conclusion that " although the broker may not be strictly a pledgee, as understood at common law, he is essentially a pledgee." By this we understand that the broker is some sort of a pledgee not known to the common law, not exactly a pledgee but still a pledgee. It is to be regretted that the Supreme Court has not come out squarely either for the New York or for the English doctrine.

LEE M. FRIEDMAN. CARRIERS. (Street Railway Transfers.) Minn. — Street railway patrons will be interested in

the decision of the Minnesota Supreme Court in Morrill v. Minneapolis St. Ry. Co., 115 N. W. Rep. 395. The action was brought for wrongful expulsion of plaintiff from one of defendant's cars. The evidence went to show that on alight ing at a transfer point, plaintiff asked for a trans fer to a designated line, and received from the conductor one which she supposed would be accepted on the cars on such line on which she subsequently took passage. The conductor on this car, however, refused to honor her transfer, and on her declining to pay another fare she was ejected from the car. One of the principal points of contention was as to whether plaintiff, as a passenger, was bound to examine the transfer slip on receiving it, to see that it was correct. The Supreme Court held that as it was the duty of the defendant company, under city regulations governing its operations, to issue transfers such as plaintiff 'requested, it was bound to see that those that were given were correct; that the rights of a passenger to whom a conductor has given a wrong transfer are in no wise affected by his negligence, and as the transfer is merely a certif icate or token, and not a new contract between the carrier and passenger, the latter has a right to continue his journey on the line for which he asked the transfer, notwithstanding the mistake of the conductor in issuing it. COPYRIGHTS. (Restraining Infringement.) U. S. Sup. Ct. — A question of infringement of the

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book of references of a mercantile agency, is passed upon by the United States Supreme Court in Dun v. Lumbermen's Credit Ass'n, 28 Sup. Ct. ReP- 335- I* appeared from the facts found in the courts below that plaintiff was the proprietor of a mercantile agency publishing a book of references containing lists of merchants, manu facturers and traders throughout the United States and Canada. Defendants published a book called the reference book of the Lumber men's Credit Ass'n. It was claimed that much of the information in defendant's book was copied from that published by plaintiff, but the evidence went to show that defendants' book of about 60,000 names contained more than 16,000 that were not found in that of plaintiff, and a great deal of additional information relative thereto. The Supreme Court, while recognizing the possibility that some of defendant's agents might have taken some advantage of plaintiff in the use of its book, held that no sufficient piracy was shown to warrant an injunction, and affirmed the decision, dismissing the bill for want of equity. CORPORATIONS. (Right to Compel Service by Electric Company.) Mass. — The decision of the Supreme Judicial Court of Massachusetts in Weld v. Gas & Electric Light Com'rs, 84 N. E. Rep. 101, and Same v. Edison Electric Illuminating Co. Id., is of considerable importance to the general public as involving the right to compel service by an electric lighting company where light is furnished to complainant by another company. There are two electric lighting corp orations holding franchises and doing business in Boston where complainant's house is located. He was formerly served by the respondent com pany but the two corporations entered into an agreement for division of territory and the right to supply complainant fell to the other company. There was no claim but that the service by it was adequate nor that the charges were excessive, but it was alleged that electric lighting companies were quasi public in nature and bound to serve all persons equally. This was recognized by the court as being true as a general principle but it held that the doctrine should not be carried so far as to take from corporations the administration of the details of their business, and as complainant showed no injury the petition to compel service was dismissed. COURTS. (Jurisdiction of Action against Foreign Sovereign.) Mass. — In Mason v. Inter colonial Ry. Co. of Canada, 83 N. E. Rep. 876, an action for personal injuries, it appeared that the railroad belonged to King Edward VII, and the question at once arose whether that fact would defeat the jurisdiction of the court. It was held