It is not uncommon for subscribers to contract for some business end either with one another or with a person or corporation to whom the subscriptions are payable. This means that the subscribers are not planning to make a gift of the money which they subscribe, but to receive an exchange for it If this exchange is requested as a return for the subscription, the subscription is supported by valid consideration. Instances of such bargains may be found where subscribers, to induce a corporation to move its plant,20 or to build a factory in a certain place,21 or to induce a municipality to make improvements,22 promise sums of money. Sometimes the bargain is unilateral, the subscribers making an offer which is accepted by the actual doing of the thing.23 In such a case it would seem upon principle that the subscription was revocable until the act requested was fully completed; 24 but many courts would doubtless hold that the incurring of expense by the offeree with a view to accepting the offer would make the subscription irrevocable.25 The bargains, however, may be bilateral. A promise being made at the outset to the subscribers as well as by them.26

17 See infra, Sec. 139.

18Beatty v. Western College, 177 111 280, 62 N. E. 432, 42 L. R. A. 797, 60 Am. St. Rep. 242; Simpson College v. Tattle, 71 Iowa, 596, 33 N. W. 74; School District Kansas City v. Sheid-ley, 138 Mo. 672,40 S. W. 656,37 L. R. A. 406, 60 Am. St. Rep. 576.

19See infra, Sec. 139.

20 Fort Wayne Electric Light Co. v. Miller, 131 Ind. 499, 30 N. E. 23, 14 L. R. A. 804; Bohn Mfg. Co. v. Lewis, 45 Minn. 164, 47 N. W. 652.

21 Gibbons v. Bente, 51 Minn. 499, S3 N. W. 756, 22 L. R. A. 80; Locke v. Tsytor, 161 N. Y. App. Div. 44, 146 N. Y. Supp. 256; Gibbons v. Grinsel.

79 Wis. 365, 48 N. W. 255; Superior Consolidated Land Co. v. Bickford, 93 Wis. 220, 67 N. W. 45.

22 Gerard v. Seattle, 73 Wash. 519, 132 Pac. 227.

22 Such were the bargains in-Curry v. Kentucky Western R. Co., 26 Ky. L. Rep. 1372, 78 S. W. 435; Fort Wayne Electric Light Co. v. Miller, 131 Ind. 499, 30 N. E. 23, 14 L. R. A. 804; Bohn Mfg. Co. v. Lewis, 45 Minn. 164, 47 N. W. 652; Locke v. Taylor, 161 N. Y. App. Div. 44, 146 N. Y. Supp. 256; Superior Consolidated Land Co. v. Bickford, 93 Wis. 220, 67 N. W. 45.

24 See supra, Sec. 60. Cf. cases cited in the preceding note.

A business subscription may take other forms. The subscribers individually may promise one another to contribute land or money to a business enterprise.27 So the mutual promises of stockholders that their voting powers shall be vested in trustees are valid reciprocal considerations for each other.28