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l64 HARVARD LAW REVIEW. that Mr. Holland frankly stays at this standpoint. He digresses, when he does digress, into saying that the English law on this point is so and-so ; and those digressions, while they cannot injure, mar the otherwise straightforward consistency of his attachment to his plan. One point in his classification seems not so good as it might be. Mr. Holland includes in rights in personam those legal phenomena which occur when a carrier or an innkeeper is bound by his calling to certain relations with travellers. Now, it is absurd, or at least useless, to discuss the right which all the world have to the service of an innkeeper as the right of special persons. It serves no purpose to say that Mr. Hol- land has a right to be carried on the Central Pacific Railway. The relation which that phrase expresses is better to be spoken of as the rail- way's duty than as the right of any member of the public. It is therefore submitted that a better classification than is the following : — R'gl^'^ i lb) In personam. ( (a) Rights in rem. Relations I {b) Rights i7i personam. (_ {c) Duties i?i rem. This last class includes such duties as a carrier's, a public official's, &c. Sir Frederick Pollock has spoken of this as a defect in classifica- tion. It is more than merely that. It has led Mr. Holland to neglect the very important third class. As one turns over the pages and sees the apt use which is made of American authorities, one is led to a regret, which cannot include blame, that Mr. Holland has not gone farther in our field. The criticism of Coke's phrase about "An Act . . . against Common Right" (and there- fore void) might well be illustrated with Mr. Justice Gray's learned note to Paxton's Case, Quincy (Mass.) 51, which treats of the American cases on that point. Some mention of the rout of the Illinois notion of degrees of negligence in the recent reports would seem worth while. So also Mr. Holland's point on page 116 about the rights of the State as such, which he illustrates by the form of prosecution. The Queen v. A. B., and People V. A. B., would be more neatly illustrated by the far more common American form, The State v. A. B., of which he seems to be unaware. And other illustrations might be multiplie*! if there were not a fear that they might be thought to indicate something wanting. The book is not wanting in good illustrations. Indeed, it is their aptness and number which make one wish that little points hke those just mentioned could have been looked on with the aid of every American doctrine or practice which could help on the good work. R. W. H. Des Contrats par Correspondance. Par Jules Valery. Paris: Thorin et Fils, 1895. pp. xvi, 461. It is very refreshing to find some of the subjects which are well threshed out in our common law jurisdictions discussed by a foreigner in the lights in which the needs of his law present them to him. In the first place the question of the time of acceptance and offer is thoroughly discussed, with a good bibliography ; and the respective the-