A solicitor at the firm, P, stole from the firm’s client account, changed it for chips at the gambling club, D, and lost it. The firm then claimed for unjust enrichment, there being no consideration for the money that he gave the club. The law was that where a victim sought to recover money from an innocent third party, the law was that the third party had to restore it unless he had given full consideration for it. Since Gaming contracts were illegal at the time, it claimed that the consideration it gave was in the form of the chips. HL said that the chips were not consideration since (1) they were inherently worthless (no different to Chappell) and were merely a means of facilitating gambling and therefore held no value in themselves (just as the wrappers in Chappell were simply a means of marketing). Clear contradiction with Chappell, which isn’t even mentioned in the ratio of HL.