The owner of an estate offered to sell for £1000. The buyer made a counter-offer of £950. The seller did not accept this offer. The buyer then offered the original £1000, but the seller did not accept. The court ruled that there was no contract in any of this; neither party had made an offer that the other accepted. Lord Langdale: it is not within the buyer’s competence to revive an offer that his previous rejection had extinguished.