Ps used D to promote their inventions and “in consideration of [his] services” they offered him 1/3 of the patents in a letter, effective immediately. Ps then tried to claim no contract either because (1) the consideration was future consideration (i.e. services in the future) or (2) was past consideration, which was defective. Bowen LJ, with others, ruled that D was to retain his share of the patents since (1) if it is future consideration then the consideration is the promise to render services, not the services themselves (which, Ps argued, were not completed) and (2) that from the evidence Bowen LJ could conclude that payment was really part of the initial deal, so that the question of past consideration is not really ruled on. He explicitly avoids ruling on whether past consideration is valid.