Smith v. Watters

Although the promise to pay a commission is not contained in a written contract between the plaintiff and defendant, it is not for that reason an insufficient memorandum under the statute.

Jacobs v The Joseph E. Copp Co., 123 Oh St, 146.

Clark on Contracts, Sec. 50, p. 116.

It is contended, however, that it is not a sufficient memorandum to satisfy the requirements of §8621 GC, because no consideration for the promise is stated in the writing.

There is a considerable conflict of opinion and diversity of holding on the question whether the memorandum of a contract falling within the statute of…