Where there was a bona fide contention between a broker and his principal as to whether the broker should be charged with the loss of a certain sum, and the broker retains and uses a check from the principal for the commissions due him, less said loss, expressed to be "in full settlement," an accord and satisfaction is established, which is a valid defense to an action by the broker for the balance of his commissions. Vorhis v. Elias, 56 N. Y. S. 134.

Finding that broker's acceptance of a check given for commissions stated on its face "in full of all demands" did not constitute an accord and satisfaction; held, sustained by the evidence, showing concealment by the owner as to whom he sold the property, and indicating bad faith on the part of the owner to deprive the broker of his commission. Elser v. Hughes, 183 I11. App. 18.