Plaintiff, who had contracted with a real estate agent to cooperate with him in selling to a third person certain property, with knowledge that such person was willing to purchase at a certain sum, induced the owner to sell for less, so that he could make the difference. Held, that he could not recover from the real estate agent his agreed proportion of the commission. Talbott v. Luckett (Md. Sup. '94), 30 A. 565.

A broker was employed to procure a purchaser for a farm within a specified time, at a price which should net the owner $11,000 and the broker $875, or such less sum as should be satisfactory to the broker's agent having charge of the transaction; the owner sold the premises to a purchaser procured by the agent of the broker for $11,000, and the purchaser paid the agent $100 for commissions. Held, that the owner, if he knew that the agent in conducting the sale violated the instructions of the broker, was liable to the broker for commissions to the extent of $875, on the ground that he was guilty of fraud on the broker. Haven v. Tartar, 124 Mo. App. 691, 102 S. W. 81. See also Secs. 99, 313, 314, 315.

A vendor of land receiving the benefits of a transaction is liable for fraudulent representations by the salesman, though he was only a sub-agent. Nelson v. Title & Trust Co., 52 Wash. 258, 100 P. 730.

A real estate agent who, in placing land for sale with sub-agent, fixed the selling price, and knowing that the sub-agent represented to purchasers that this was the lowest price the owner would take, received the benefit of such representation, was chargeable with the damage to the purchasers from their reliance thereon. Estes v. Crosby, 175 N. W. 933, amend. or man. den., 177 N. W. 512, - Wis. Sup. - .