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270 HARVARD LAW REVIEW. harmony. Whether the power will be exercised even to this extent is not yet settled, and it may be that the courts will decide that every one using this force in the public streets must exercise ingenuity to protect himself from the effect of the use of the same force for lawful ends and by lawful means, only insisting that each must use the best appliances practically available and avoid negli- gence and wanton injury. With respect to this conflict with the telephone companies, and also that with the land-owners, it may safely be said, in the light of experience, that the new methods of using the streets will prevail, and that the courts may be trusted to protect the substantial property rights of individuals, even though they may not assure them against the inconveniences of living in a very busy world. Edward Q. Keasbey, Newark, N. J.