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Contracts Keyed to Dawson
Davis v. General Foods Corporation
Citation:
21 F. Supp. 445 (S.D.N.Y. 1937)Facts
In 1933, Jane Davis submitted to General Foods Corporation an unsolicited idea for a radio program featuring cooking recipes and household suggestions. Her submission included a detailed outline of the proposed program format. Davis did not expressly request compensation but claimed she expected payment if her idea was used. General Foods acknowledged receipt of her submission with a form letter but did not promise payment. Approximately two years later, General Foods began broadcasting a radio program called “Frances Lee Barton’s Kitchen Party,” which Davis claimed was substantially similar to her proposed program. Davis alleged that General Foods had appropriated her idea without compensation, constituting both breach of an implied contract and unjust enrichment.
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