Williamson v. New York Central Railroad

Action for breach of an implied contract to compensate plaintiff for the disclosure to defendants of an alleged novel idea for the production and staging of a miniature railroad at the New York World’s Fair.

The letters between the parties upon which the plaintiff’s claim is predicated do not constitute an express contract to compensate the plaintiff. An implied contract to do so does not arise therefrom, because they merely contain an abstract idea which may not be made the subject of property right in the absence of protection thereof by an express contract prior to disclosure. (Bristol v.…