Plaintiff advertising firm submitted advertising plans at the invitation of defendant brewing company, in the hope of getting a contract to handle its advertising. Defendant awarded the contract to another, but appropriated and used extensively a slogan, "The Beer of the Century," from the material submitted by plaintiff, who sued to recover the value thereof. Held, that plaintiff was entitled to recover, on an implied contract to pay for the services, the value to defendant of the fruits of the services. How. J. Ryan & Associates, Inc. v. Century Brewing Assn., 185 Wash. 600, 55 P. (2d) 1053 (1936).

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