In addition to the buyer's placing the goods at the disposal of the purchaser in a deliverable state, or delivering the goods to the carrier, or other agent of the buyer with notice of the same to the purchaser where notice is necessary, a delivery may also be made by the delivery of the keys of the building, in which the goods are stored, by the buyer to the seller, or where intent is also shown to surrender possession of the goods, this has been deemed a delivery, so as to pass title. And it has been held that such a mode of delivery is good as against a creditor of the seller, who subsequently attempts to take the goods on an attachment or execution.15 So when a ship is in a foreign port or on the high seas, a transfer of the ship may be made by assignment of the bill of sale, and a delivery of the assignment, with other papers relating to the vessel, and the buyer takes actual possession as soon as the ship comes to port, or circumstances will allow.16 Delivery may be made by installments, only where the parties to the contract of sale have so agreed, and where from the nature of sale it would be unreasonable to expect the whole to be delivered at one time, the right to deliver in installments may be implied.

13 Larkin vs. Mitchell, 42 Mich., 296.

14 Norrington vs. Wright, 115 U. S.,

188. 15 Kellogg's Newspaper Co. vs Peterson, 162 I11. 156; Packard vs. Dunsmore, 11 dish., 282.