In the case of Austin v. Burge (156 Mo.App. 286, 137 S.W. 618 (Mo.App. 1911)), Burge received a gift subscription of Austin’s newspaper. Once the gift subscription ran out, Austin continued to send the paper, and billed Burge. The first two times, Burge paid the bill and requested that the deliveries stop. Austin continued to deliver newspapers and Burge refused to pay. Austin eventually sued for non-payment. The Trial Court found for Burge, saying that he never had a contract with Austin. However, the Appellate Court reversed saying that since Burge was still accepting the papers, there was an implicit contract for him to keep paying for them.