mercantile company upon which the bill was drawn failed to
pay it, whereupon the parties fell into a dispute about the matter of
damages, and the magistrates of Bruges wrote to those of Barcelona,
setting forth this bill with the facts of the case, and requesting
information upon the usage respecting bills of exchange in their city.

A bill drawn in England about the year 1500 bears less resemblance to
the form now used, and instead of commencing and ending with the devout
expressions of the Italian bill, it has the formal words, "Be it known
to all M'e y't I," etc., and "hereto I bynde me myn executours and all
my Goodis, wheresoever they may be founde, in Wytnesse whereof I have
written and sealyed this Byll, the X Day of," etc. It was made payable
to a person named, "or to the Bringer of this Byll."

Bills of exchange were first used only for the benefit of a specified
payee, but it was not long before the element of negotiability was
added to foreign bills, which, thus perfected, became at once the
indispensable instruments of commerce which they now are. The
negotiability of inland bills and of promissory notes was not recognized
till long afterwards. In England, inland bills were not used in any form
till about the middle of the seventeenth century; and Lord Holt, in a
case reported half a century later, said he remembered the time when
actions upon inland bills first began. Indeed, the earliest case in
which foreign bills of exchange are mentioned in the English Reports is
as late as the first year of the reign of James I., though they appear
to have been known to the courts in the preceding reign of Elizabeth,
for there are extant precedents of declarations upon them of that
period. The earliest reported case of an inland bill occurs in 1663. It
appears that the negotiability of promissory notes was a matter of doubt
with the Court of Queen's Bench as late as 1702. The court seem to have
felt very little confidence in their own opinion upon the question; for
Chief Justice Holt, after urging his opinion against the negotiability
of such instruments, took occasion to speak with two or three of the
most famous merchants in London, as to the consequences it was alleged
would follow from obstructing their negotiability; and on another day he
says that they had told him it was very frequent with them to make such
notes, and that they looked upon them as bills of exchange, and that
they had been used a matter of thirt