This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
Ballinger's Acts and Statutes, Sec. 4576, provides that an agreement authorizing or employing a broker to sell or purchase real estate for compensation or commission shall be void unless the contract or some note or memorandum thereof be in writing, signed by the party to be charged; in an action by a broker he relied on a memorandum addressed to himself reading: "Enclosed find contract which S. wishes signed by F. and confirmed by E. Advise us when abstract is ready," and signed by one of the defendants, S. being the other defendant; F. having represented the owner of the land and E. being the owner, and the abstract being an abstract of title to the land. Held, that the memorandum was insufficient under the statute. Keith v. Smith, 46 Wash. 131, 89 P. 473; McCrea v. Ogden (Wash. Sup. '09), 103 P. 788; Mendenhall v. Rose (Sup. Ct. Cal. '93), 33 P. 884; Phillips v. Jones, 39 Ind. App. 626, 80 N. E. 555.
 
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