THE ORCHID REVIEW. 
VoL. AlVal JUNE, 1906. [No. 162. 
LAW NOTES. 
LEEMANN V. LINDEN & Co.—The Journal des Tribunaux for April 12th 
reports the judgment in this case, of which an outline was given at page 61 
of our last volume, the essential point being that five Odontoglossum 
crispums were purchased for £1,200, on the strength of coloured drawings 
supplied by the defendant, but on flowering were, according to the plaintiff, 
very inferior. 
At the preliminary hearing (on February 28th, 1905) it was established 
that when the plaintiff complained that the flowers of three of the plants 
in question, which had flowered in his houses, did not agree with the re- 
productions which had served as the basis of the sale, the defendants did 
not contest the identity of these plants with those delivered by them. At 
this hearing the following facts, which are not disputed, were also 
ascertained :— 
On December gth, 1903, the plaintiff's wife, in his absence, wrote to 
M. Linden saying that the variety ‘“‘ Constellatum” had flowered, but that 
the painting was completely different, representing a flower both larger and 
with more colour. 
On December 11th, 1903, the defendant replied verbally that this was 
not astonishing, considering the time of year in which the flowering took 
place, the days being the shortest and darkest in the year. 
On December 15th, 1903, the defendant, having received a flower which 
had been sent to him, declared that it differed from the flower obtained 
when the plants last flowered with him, but reiterated that this was not 
surprising, considering the time of year at which it flowered, he himself 
having had many similar cases. 
On April 19th, 1904, the plaintiff notified the defendants that the 
Varieties “Calos” and “‘Funambulum” had flowered, and were also not 
true. 
On April 2oth the defendants wrote protesting that something very 
obscure had taken place, which required clearing up, and that it was neces- 
Sary to investigate why the plants had not flowered true in the plaintiff's 
161 
