If the offeror and the offeree are not in personal communication, the mail and the telegraph are the practicable methods of communication; and the courts have had no hesitation in recognizing the validity of simple contracts thus made.1 The difficulty has been in determining the time at which the various acts in a contract by mail or by telegraph were to be regarded as taking effect. An offer is regarded as taking effect from the time that it is received and not from the time that it is mailed.2 An acceptance, mailed after the offer has been mailed and before it has been received, is inoperative.3 This is merely a literal application of the rule that an offer, in order to be operative, must be communicated.4