If there is an independent consideration for A's promise to furnish goods or services at a certain fixed price,1 or if A's promise is under seal,2 he can not revoke such promise. So a promise by A to drive all the logs that B might buy in a certain river is valid where B, though he does not agree to buy any logs, releases a claim against A as a part of such contract.3 A's promise to advertise B's goods is consideration for B's promise to furnish as many of such goods as A might order.4 If B promises to order at least a minimum quantity, A's promise to furnish such goods as B may order, is supported by a sufficient consideration.5 A contract by which a miner should pay for making a spur track, which was to be the property of the railway company, and which the railway company should operate only as long as the business done thereon should, in the judgment of the railway company, pay therefor, is, though one-sided, so far valid, that the railway company may, after building such spur track, recover from the miner the cost of building it.6 A contract by a railway to haul, at a certain rate, whatever logs a logging company might offer, if the act of the logging company in altering its road is a consideration therefor, is valid.7 These are cases of offers for value which are usually held to be irrevocable.8 In such cases acceptance of the irrevocable offer makes a contract, even if the offeror has attempted to revoke his offer.9

4 Wright v. Vaughan, 137 Ga. 52, 72 S. E. 412.

5 Feuchtwanger v. Manitowoc Malting Co., 187 Fed. 713, 109 C. C. A. 461 [reversing, Manitowoc Malting Co. v. Feuchtwanger, 169 Fed. 983].

6Sandeen v. Russell Lumber Co., 45 Mont. 273, 122 Pac. 913.

7 Doolittle v. Callender, 88 Neb. 747, 130 N. W. 436.

8 Keopple v. National Wagonstock Co., 104 Ark. 466, 149 S. W. 75.

9 C. H. Young Co. v. Springer, 113 Minn. 382, 129 N. W. 773.

10Tweedie Trading Co. v. Parlin & Orendorff Co., 204 Fed. 50.

1 California. Calanchini v. Branstet-ter, 84 Cal. 249, 24 Pac. 149.

Minnesota. Staples v. O'Neal, 64 Minn. 27, 65 N. W. 1083.

Nebraska. Carter White Lead Co. v. Kinlin, 47 Neb. 409, 66 N. W. 536.

Virginia. New Idea Spreader Co. v. Rogers, 122 Va. 54, 94 S. E. 351.

Washington. Sultan Ry. & Timber Co. v. Great Northern Ry. Co., 58 Wash. 604, 109 Pac. 320 (hearing en banc denied, 109 Pac. 1020).

2 See Sec. 127 and ch. XXXIX.

3 Mississippi River Logging Co. v. Robson, 69 Fed. 773, 16 C. C. A. 400.

4 New Idea Spreader Co. v. Rogers, 122 Va. 54, 94 S. E. 351. Advertising land is consideration for an option. Sixta v. Ontonagon Valley Land Co., 148 Wis. 186, 134 N. W. 341.