The requirement that a revocation must be received in order to be effectual creates difficulty where an offer has been extended to a large and indefinite class of persons, as an offer of reward issued by advertisement to the public. In such a case it is obviously impossible to communicate' a change of purpose to every one who may have seen the original offer. The only alternatives possible for the law are either to admit that such an offer is irrevocable as to any person who is not actually notified of the revocation, or to treat a reasonable effort to bring notice borne to the public by publishing the revocation as fully, and so far as possible in the same way, as the original offer as an effectual revocation. The Supreme Court of the United States has chosen the latter alternative.65 But where the reward for the apprehension of a murderer was offered at the place where the shooting occurred and at a railroad station, an offer of a reward in different terms at another station did not constitute a revocation of the first offer.66
63In Offord v. Davits, 12 C. B. (N. S.) 748, an offer was made to guarantee such of B's bills of exchange as the plaintiff might discount within twelve months to the extent of £600. Some discounts took place, but subsequently, within the year, the offer was revoked. The court held the offeror not bound by discounts made after the revocation. The same result was reached in Grob v. Gross, 83 N. J. L. 430,84 Atl. 1064, where the promise was to guarantee payment for goods gold to another to any amount up to 8500. In Great Northern Ry. Co. v Witham, L. R. 9 C. P. 16, there was an offer to supply the railway company with such quantities of certain specified goods as it might order, from time to time, at certain fixed prices. It was held that the defendant was bound to furnish goods which had been ordered by the railway in conformity with the offer, but Brett, J., said: "I agree that this judgment does not decide the question whether the defendant might have absolved himself from further performance of the contract by giving notice." See also Buick Motor Co. v. Thompson, 138 Ga. 252, 75 S. E. 354, 356; Picker v. Fitzelle, 60 N. Y. App. D. 451, 69 N. Y. S. 902; White v. Allen-Kingston 4c. Co., 69 N. Y. Misc, 627, 126 N. Y. Supp. 160; Butchers' Advocate Co. v. Berkof, 94 N. Y. Misc. 200, 158 N. Y. S. 160 (cf. North Side News Co. p. Cypres, 75 N. Y. Misc. 129, 132 N. Y. S. 806; Post v. Prank, 75 N. Y. Misc. 130, 132 N. Y. S. 807); American Steel & Wire Co. v. Copeland, 159 N. C. 556, 75 S. E. 1002.
64American Publishing Co. v. Walker, 87 Mo. App. 503. In this case an offer for certain publishing matter weekly, for the term of one year, at a fixed price per week, was held to create a single contract for the year incapable of revocation after acceptance. Similar cases are Imperial Curtain Co. v. Strauss, 135 N. Y. S. 577; Post v. Frank, 132 N. Y. Supp. 807, 75 N. Y. Misc. 130. See also cases of divisible contracts, infra, Sec.Sec. 861, et seq.