At common law a seal was necessary in the execution of a valid deed,204 but in many states this requirement has been abolished.205 A. seal is defined to be "an impression on wax or wafer or some other tenacious substance capable of being impressed." 206 But a seal stamped on paper has been held good.207 In many states a seal

188 Herrick v. Malin, 22 Wend. (N. Y.) 388; Waring v. Smyth, 2 Barb. Ch, (N. Y.) 133; Johnson v. Moore, 33 Kan. 90, 5 Pac. 406.

199 Hatch v. Hatch. 9 Mass. 307.

200 Herriek v. Malin, 22 Wend. (N. Y.) 388; Holton v. Kemp, 81 Mo. 661; Van Horn v. Bell, 11 Iowa, 465.

201 Montag v. Linn, 23 111. 503.

202 School Committee v. Kesler, 67 N. C. 443; Kimball v. Eaton, 8 N. H. 391.

203 Jackson v. Hayner, 12 Johns. (N. Y.) 469; Morrison v. Morrison, 27 Grat, (Va.) 190; Lyons v. Van Riper, 26 N. J. Eq. 337.

204 Davis v. Brandon, 1 How. (Miss.) 154; Grandin y. Hernandez, 29 Hon, 309; Le Franc v. Richmond, 5 Sawy. 603, Fed. Cas. No. 8,209. But see Moss t. Anderson, 7 Mo. 337.

205 l stim. Am. St. Law, §§ 421, 1564. Such statutes are not retroactive. Wisdom v. Reeves (Ala.) 18 South. 13.

206 Warren v. Lynch, 5 Johns. (N. Y.) 239; Tasker v. Bartlett, 5 Cush. (Mass.) 359, 364; Bradford v. Randall, 5 Pick. (Mass.) 496.

207 Pierce v. Indscth, 106 U. S. 546, 1 Sup. Ct. 418; Pillow v. Roberts, 13 How. 473. But see Farmers' & Manufacturers' Bank v. Haight, 3 Hill (X. Y.) 493. The printed device "[L. S.]" has been held sufficient Williams v. Starr, 5 Wis. 534, 549.

430 title. (Ch. 16 may be supplied by a mere scroll, made with the pen.209 In such case the instrument must declare that a seal is attached.210 Corporations usually have seals of their own, though they may adopt any other in executing a deed.211 The seal of a corporation can only be attached by some one having authority.212 Where several persons execute the same deed, they may all use one seal.213