PLACE    OF    ACCEPTANCE  59

town,  where  A.  also  had  a  place  of  business.  This  was  held
not  to  be  a  sufficient  acceptance.^*  The  Court  said;  "What-
ever uncertainty  there  might  have  been  as  to  the  time  when
the  answer  would  be  received,  there  was  none  as  to  the  place
to  which  it  was  to  be  sent,  this  was  distinctly  indicated  by
the  mode  pointed  out  for  the  conveyance  of  the  answer.  The
place  therefore  to  which  the  answer  was  to  be  sent,  consti-
tuted an  essential  part  of  the  offer."

"Letter  follows."  The  offeree  may  reply  to  an  offer  by  a
brief  telegram  saying,  "Accept  your  offer,  letter  follows,"  or
using  some  such  expression,  and  when  the  letter  arrives,  it
may  be  found  to  contain  certain  modifications  or  not  to  be
an  unqualified  acceptance.  In  such  a  case,  the  question  is
whether  an  absolute  contract  has  been  made  in  precise  con-
formity with  the  offer,  binding  on  both  parties,  or  whether
such  an  answer  is  to  be  regarded  as  insufficient,  authorizing
the  offeror  either  to  revoke  the  offer  or  to  treat  it  as  a  rejec-
tion or  counter  offer.  A  writer  says :  "One  should  ask  what
meaning  the  offeror  could  have  legitimately  attributed  to  the
expression,  letter  follows.  These  words  are  susceptible  of
two  interpretations, — they  could  signify  that  the  sender  of
the  telegram  accepts  provisionally  or  in  substance,  but  with
certain  reservations  expressed  in  his  letter,  and  subordinates
the  final  formation  of  the  contract  to  the  acceptance  of  the
conditions  which  he  will  indicate  in  the  letter.  They  may
also  simply  mean  that  the  letter  announced  will  contain  direc-
tions as  to  the  manner  of  carrying  out  the  contract.  If
according  to  the  intention  of  the  acceptor  these  words  have
this  latter  meaning,  no  difficulity  can  arise  and  the  contract
is  irrevovably  made.  But  on  the  other  hand,  when  they  were
designed  to  show  that  the  consent  given  to  the  offer  is  only
conditional,  then  the  question  arises  whether  the  contract
was  made  and  the  offeree  can  be  compelled  to  perform  it.
