It is possible for an offer to be made, not to any specific person, identified as the offeree when the offer is made, but to any person, then indefinite, who shall later be ascertained. Such offers are valid.1 A common type of such offers is the offer of a reward for the doing of some specified act. The doing of the act serves the quadruple purpose of consideration, acceptance, identification of the offeree,2 and performance. An offer of a subscription for a certain purpose, not made to any specified person may be accepted by the person for whose benefit it was made.3 In some cases an offer may be made to a person not in existence, which offer if still outstanding may be accepted by such person after coming into existence. Thus an offer to a corporation, made before it is formed, may be accepted by it afterwards.4 If an offer is made to the owners of certain realty, whoever they might be, to pay a certain subscription if a stock exchange were located there, free of rent, such offer becomes a contract with the owner of the realty who performs eventually.5 So a corporation may become liable for services of a promoter by accepting the benefit of them after it is incorporated.6 If an offer for value has been made to sell land, and the offeree dies before such offer is accepted, his administrator is the proper person to accept such offer.7

6 Alabama. Wilkins v. Hardaway, 159 Ala. 565, 48 So. 678.

Georgia. Robinson v. Perry, 21 Ga. 183, 68 Am. Dec. 455.

Kentucky. Chesbrough v. Vizard Investment Co., 156 Ky. 140, 160 S. W. 725.

Michigan. Cameron v. Shumway, 149 Mich. 634, 113 N. W. 287.

Oregon. House v. Jackson, 24 Or. 89, 32 Ac. 1027.

Wisconsin. Kreutzer v. Lynch, 122 Wis. 474, 100 N. W. 887.

7 Rease v. Kittle, 56 W. Va. 269, 49 S. E. 150.

8 See ch. LXXI.

9 Rice v. Gibbs, 40 Neb. 264, 58 N.

W. 724 [overruling Rice v. Gibbs, 33 Neb. 460, 50 N. W. 436].

10 Myers v. Stone, 128 la. 10, 111 Am. St. Rep. 180, 102 N. W. 507.

11 McQueen v. Chouteau's Heirs, 20 Mo. 222, 64 Am. Dec. 178.

12 Newton v. Newton, 11 R. I. 390, 23 Am. Rep. 476.

1 Hopkins v. Upshur, 20 Tex. 89, 70 Am. Dec. 375; Strong v. Eld ridge, 8 Wash. 595, 36 Ac. 696; Lathrop v. Knapp, 27 Wis. 222.

2 Central, etc., Co. v. Cheatham, 85 Ala. 292, 7 Am. St. Rep. 48, 4 So. 828; Wilson v. Stump, 103 Cal. 255, 42 Am. St. Rep. Ill, 37 Ac. 151; Reif v. Paige, 55 Wis. 496, 42 Am. Rep. 731, 13 N. W. 473.