Wood v. Lucy, Lady Duff-Gordon

Lady Duff-Gordon (defendant) granted Wood (plaintiff) the exclusive right to endorse others' clothing designs using her name and to market and sell her own designs, in exchange for 50% of resulting profits; Wood agreed to keep accounting records and secure necessary patents, copyrights, and trademarks. She later endorsed another company's designs, and Wood sued for breach. She argued the contract lacked consideration since it never explicitly obligated Wood to actually do anything to earn the exclusive rights he'd been given; the trial court disagreed, but the Appellate Division reversed in her favor.

Whether a contract may be enforced when there is no explicit promise of consideration in its terms, and whether a promise to use reasonable efforts may be implied from the entire circumstances of the contract.