Performing work and labor which the party performing was not otherwise bound to do, forms a consideration for a promise made in return for such work and labor.1 Examples of such considerations are agreements either express2 or implied,3 to work as agent or employe, doing work not lOSteinman v. Magnus, 11 East 390; Jenness v. Lane, 26 Me. 475.

11 Schmidt v. Ludwig, 26 Minn. 85, 1 N. W. 803.

12 Post v. First National Bank, 138 111. 559, 28 N. E. 978.

13 See Sec. 596.

1 Colorado. Patrick v. Morrow, 33 Colo. 509, 108 Am. St. Rep. 107, 81 Pac. 242.

Indiana. Steves v. Frazee, 19 Ind. App. 284, 49 N. . 385.

Kentucky. Harper v. Ry. Co. (Ky:), 22 S. W. 849.

Louisiana. Murray v. Kennedy, 15 La. Ann. 385, 77 Am. Dec. 189.

Michigan. Johnston v. Stearns, 160 Mich. 247, 125 N. W. 29.

Missouri. Crosby v. Emerson-Brant-ingham Implement Co. (Ma), 189 S. W. 506.

New York. Cowee v. Cornell, 75 N. Y. 91, 31 Am. Rep. 428.

Oklahoma. Fairchild v. Cartwright (Okla.), 178 Pac. 333.

Pennsylvania. McFeaters v. Patti-son, 188 Pa. St. 270, 41 Atl. 609.

2 Forbes v. Bushnell, 47 Minn. 402, 50 N. W. 368. And the additional promise of the take a certain amount of goods is still more clearly a consideration. Condit v. Bergmeier, 63 Fed. 937; Weiboldt v. Fashion Co., 80 111. App. 67.

3 Thus it is a consideration for a promise to pay commissions. Travelers' Ins. Co. v. Parker, 92 Md. 22, 47 Atl. 1042; or to give the agent exclusive territory: Condit v. Bergmeier, 63 Fed. 937; Mueller v. Spring Co., 88 Mich. 390, 50 N. W. 319.

called for by pre-existing contract;4 making repairs;5 perfecting a patent;6 sinking an oil well,7 and furnishing water to cattle.8 So furnishing service by quasi-public corporations, such as by a waterworks company,9 or a gas company,10 operating a street railway,11 or changing the service from horse cars to electric cars,12 are sufficient considerations.

Support, whether of the promisor or of a third person, is a valuable consideration for a promise based thereon.13 Taking care of a third person is sufficient consideration.14 Care and support amount to a consideration for a promise to discharge a note and to cancel a mortgage.15