If the offeror attempts by letter or by telegram to revoke an offer which is already made, such revocation is not operative until such letter or telegram has reached the offeree in the ordinary course of business.1 Under a statute, however, which provides in effect that notice of revocation is to be deemed to be fully communicated between the parties as soon as the party who revokes his offer has placed his notice of revocation in the course of transmission to the person to whom the offer is made, such offer is revoked as soon as the notice of revocation is mailed; and an acceptance made after such notice of revocation is mailed is too late, even though it is made before such letter of revocation is received.2 Under the foregoing common-law rules, a letter which contains a new offer, a revocation of a former offer, and an acceptance of an offer made by the adversary party will be operative from the date of mailing as to the acceptance and from the date of receipt for other purposes. Such distinction is, however, not necessarily arbitrary or illogical. One who makes an offer, knowing that it is to be accepted when the offeree is not in personal communication with the offeror, contemplates acceptance by mail or telegraph with the corresponding legal consequences; while one to whom an offer has been made does not ordinarily contemplate revocation at all; and one to whom an offer is to be made, does not contemplate the making of such offer by mail until it is received.

5 Casco National Bank v. Shaw, 79 Me. 376, 1 Am. St. Rep. 319, 10 Atl. 67; Johnson v. Brown, 154 Mass. 105, 27 N. E. 994; Wood v. Callaghan, 61 Mich. 402, 1 Am. St. Rep. 597, 28 N. W. 162.

6 Banco de Sonora v. Bankers' Mutual Casualty Co., 124 la. 576, 104 Am. St. Rep. 367, 100 N. W. 532.

Contra on an earlier hearing: Banco de Sonora v. Bankers Mutual Casualty Co. (la.), 95 N. W. 232.

7 Townsend v. Auld, 10 Misc. (N. Y.) 343, 31 N. T. Supp. 29; In re London & Northern Bank (1900), 1 Ch. 220.

8 In re London & Northern Bank (1900), 1 Ch. 200.

9 Pearce v. Langfit, 101 Pa. St. 507, 47 Am. Rep. 737.

10 Maclay v. Harvey, 90 111. 525, 32 Am. Rep. 35.

1 Webb v. Sharman, 34 U. C. Q. B. 410; Perry v. Iron Co., 15 R. I. 380, 2 Am. St. Rep. 902, 5 Atl. 632.

2 Summers v. Hibbard, 153 III. 102, 46 Am. St. Rep. 872, 38 N. E. 899; Haines v. Dearborn, 199 Pa. St. 474, 49 Atl. 319.

3 Noel Construction Co. v. Atlas Portland Cement Co., 103 Md. 209, 68 Atl. 384.