The defendant put an automobile sales company in possession of several used automobiles, the sales company to exhibit them and obtain offers for them, but to sell only on written order from the defendant. The sales company sold an auto to the plaintiff without such written order. Held, that the plaintiff had good title, the requirement of a written order as a prerequisite to the power to sell being a secret instruction not binding on an innocent purchaser for value. Simons v. Northeastern Finance Corp. (Mass. 1930) 171 N.E. 643.