But is the loss of a merely promised advantage a loss that ought to be a matter of legal inquiry and repair? In the promise to pay money, and in papers transferring property from one person to another, it is requisite that a “consideration” be expressed: the person claiming value from another must show that value was given. What is the consideration in the case of a marriage-promise? What computable value has the defendant in a breach of promise case received that the plaintiff could, or if she could would care to, estimate in dollars and cents? Would she undertake to submit an itemized bill? As a rule, the promiser of marriage receives nothing for which the performance of his promise would be an “equivalent” in the commercial sense. True, he obtains by his promise certain privileges which (it is said) he deems precious; but all the accepted authorities on this subject declare that in the exercise of these he imparts no small satisfaction to the person bestowing them. Accurately speaking, then, a promise of marriage is a promise without consideration; and whatever merely sentimental injuries result from its infraction might justly be squared by a merely sentimental reparation. Perhaps it would be enough if the injured plaintiff in a breach of promise suit were awarded the illusory advantage but acceptable gratification of wigging the defendant’s attorney. It may be said that the defendant’s equivalent for his promise was the lady’s tender of such services as wives perform for husbands—among which the peasant-born humorist of the period loves to enumerate such mysterious functions as “building the fire” and assisting to search for the soap in the bath-tub. But it must not be overlooked that this tender is itself only a promise whereof the performance fails, along with that of the one for which it is given in exchange: the fire remains unbuilded and the soap is lost. One unfulfilled promise is no better than another. Nay, it is not so good.