582 HARVARD LAW REVIEW See 13 Harv. L. Rev. 225. But an agreement between a landowner and an outsider for payment for planting trees or making other improvements to land is generally held not to be within the statute. Frear v. Hardenbergh, 5 Johns. (N. Y.) 272; Lower v. Winters, 7 Cow. (N. Y.) 263. But see Falmouth V. Thomas, i Cromp. & M. 89, 108. The reasoning is that such an agreement is simply a contract for payment for certain labor and chattels to be applied in a given manner, and does not effect a transfer of any interest in the land. The agreement in the principal case comes within this reasoning, so that it seems unnecessary to resort to equitable principles to justify the recovery. Torts — Unfair Competition — Piracy of News. — The Associated Press brought a bill in equity against the International News Service asking that the latter be enjoined, inter alia, from copying news from bulletin boards and early editions of complainant's newspapers and selling this, either bodily or after rewriting it, to defendant's customers, until its commercial value as news to the complainant and aU of its members had passed away. Held, such acts constitute unfair competition, complainant has a Umited property in news gathered by it, and a preliminary injunction will be granted. International News Service v. The Associated Press, U. S. Sup. Ct., December 23 (October Term, No. 221), 1918. For a discussion of this case, see Notes, page 566. BOOK REVIEWS A Short Treatise on Canadian Constitutional Law. By A. H. F. Le- froy. Toronto: Carswell Company. $4.00. Mr. Lefroy has written a valuable and informative book. American lawyers are in general lamentably ignorant of the working of federalism in the two great EngUsh commonwealths; and it has been in the past the excuse that books like Mr. Lefroy's larger treatise on Canada and Mr. Moore's admirable volume are too large for anyone save the student of details. Mr. Lefroy's book removes the basis for this excuse, so far, at least, as Canada is con- cerned. In three hundred pages he gives us an admirable summary of the main legal h5TX)theses of Canadian federaUsm and a mass of notes which refer to the more important cases on the subject. Professor Kennedy of Toronto contributes a useful historical introduction in which Canadian constitution- alism prior to 1867 is discussed. One or two observations of special importance may be noted. Legally the question meets us on the threshold as to whether Canada is to be regarded as a federation at all. If ^. G. for Australia v. Colonial Sugar Refining Co., [1914] A. C. 237, is to be accepted as good law, Canada is to be regarded as simply a rather striking instance of decentralization in which old powers were redistributed. Mr. Lefroy argues that it is impossible to accept this point of view. It mistakes a confederation for what may be the same thing in result, but utterly different in its origin. The Federation Act of 1867 clearly intended to recognize national unity in the milieu of a very complete right to local self- government, exactly as in the case of the Constitution of the United States. It is weU known that Mr. Lefroy is the urgent advocate of a complete dis- tinction between American and Canadian federalism, and it is worth while to summarize the grounds of his argument, (i) In Canada there is no separation of powers. The existence, both in the federal and provincial governments, of the English parliamentary system, with its fusion of executive and legisla- ture, marks a fundamental difference from the system of America. (2) There
