"While there is little authority on the point, there seems no reason why a written contract may not be made upon any material which can receive a legible impression of any kind; and there seems to be no reason why any material which is capable of making a legible impression may not be used as a means of writing. Paper is now the common material upon which to write, and ink the common material with which writing is done, whether it is applied by means of a pen or a typewriter. Writing in lead pencil has, however, received the sanction of the court,1 as where a signature made with a lead pencil has been held valid, even in case of negotiable contracts which must be in writing.2 So a signature to a promissory note may be printed,3 as where a signature is lithographed in facsimile and printed on the contract.4

1 See Ch. XXXV.

1 Myers v. Yanderbelt, 84 Pa. St. 510; 24 Am. Rep. 227; Reed v. Roark, 14 Tex. 329; 65 Am. Dec.


2 Brown v. Bank, 6 Hill (X. Y.) 443; 41 Am. Dee. 755.

3 Weston v. Myers, 33 Ill. 424.

4 Pennington v. Baehr, 48 Cal. 565.