RE CASEY'S PATENTS, STEWART V CASEY (1892) PAST CONSIDERATION IS NOT GOOD CONSIDERATION

'We [Stewart and another] now have pleasure in stating that in consideration of your
[Casey's][past] services as the practical manager in working both our patents..., we
hereby agree to give you one third share of the patents.'

A and B, joint owners of certain patents, wrote to C as follows: 'In consideration of your services as the practical manager in working both our patents, we hereby agree to give you one-third share of the patents, the same to take effect from this date.' A and B afterwards deposited the letters patent with C to assist him in effecting a sale of the patents, which however did not take place. C registered the above letter, and claimed to retain possession of the letters patent as a co-owner of a third share therein: Held the letter was an immediate equitable assignment of an interest in the patent, and not defective for want of consideration.

The promise to render future services, if an effectual…