(1) A broker engaged to obtain a purchaser, who claims a commission, though the sale was prevented because of an alleged defect of title, has the burden of proving that his principal failed to discharge an obligation resting upon him with reference to making the title good. Reeder v. Epps, 166 S. W. 747, 112 Ark. 506.

(2) Where, in a broker's action for commission, plaintiff relies, under authority of Civil Code, Sec. 1559, upon a contract made for his benefit, and not upon the employment, and where defendant pleads employment as a basis of the defense, resting on the confidential relations, the burden is on defendant to prove such employment. Konda v. Fay, 136 P. 514, 22 Cal. App. 722.

(3) In a suit for commissions on sale of real estate, burden is on plaintiff to show a definite offer to sell by defendant and acceptance by the prospective purchaser, and that defendant, without just reasons, refused to convey. Hauch v. Bonnabel, 64 S. 795, 134 La. 847.

(4) Where an owner, after giving to a broker an exclusive agency for sixty days to sell real estate, at a specified sum, for the usual commission, sold the property before the expiration of the sixty days, for a less sum, to one not procured by the broker, the commission contracted for was prima facie the damages to the broker, treating the contract as performed, and the owner had the burden of showing, to reduce the damages, that in all reasonable probability the broker could not have procured a purchaser within the time specified for the specified price. Norman v. Vandenberg, 138 S. W. 47, 157 Mo. App. 488.

(5) Where a sale negotiated by brokers failed because of the outstanding liens on the property, the burden was on the owners, in a suit for commissions, to show that the brokers had knowledge of the situation when they procured a purchaser. Willson v. Crawford, 130 S. W. 227, 61 Tex. Civ. App. 580.

(6) A broker, to recover the reasonable value of services in procuring a customer to whom the owner sold at a price less than that fixed in the contract of employment, must show the reasonable value of the services. Martin v. Jeffries, 172 S. W. 148, - Tex. Civ. App. - .

(7) Owner employing a broker to procure a purchaser has the burden of proving the fraud of the broker, to defeat an action by the broker on a note for his commissions. Martineau v. Hanson, 155 P. 432, 47 Utah, 549.

(8) The rule requiring a broker suing for a commission for procuring a purchaser to show that the purchaser was ready, able and willing to buy on terms satisfactory to the owner, applies only where owner has refused to consummate the sale, and not where the property has been actually sold on satisfactory terms. Weisels-Gerhart Real Estate Co. v. Epstein, 137 S. W. 326, 157 Mo. App. 101.

(9) Party seeking to defeat broker's right to commission on contract of exchange of lands incumbered by a mortgage, on the . ground that the contract was invalid, was bound to show that purchase was made by the broker with this permanent capital or deposits. Genatt v. Robinson, 165 N. Y. Sup. 464.

(10) In a broker's suit for commissions on exchange of land, in which intervenors claimed a portion of commissions, and there were no material issues between plaintiff and defendant, intervenors had burden of proof to establish their allegations, that there was a universal custom, where more than two brokers are interested, to pool commissions, and that they had such agreement with plaintiff. Knight Realty Co. v. Williams, 193 S. W. 168, - Tex. Civ. App. - .

(11) In an action for damages for breach of contract in selling land, where plaintiffs relied on ratification by defendant of agent's contract to sell, burden was on them to prove ratification. Crumpacker v. Jeffrey, 115 N. E. 62, - Ind. App. - .

(12) Plaintiff has burden of proving consideration for defendant's written agreement to pay a certain sum for services connected with the sale of certain property, payment to be made upon completion of sale, although defendant had made partial payment, and had sold property, though not through plaintiff's efforts. Dennis v. Vinton, 165 N. W. 603, - Mich. Sup. - .

(13) In broker's action for commission, burden of proving terms of brokerage contract was upon broker, principal not being required to prove any part thereof. Jackson v. Kohler, 124 N. E. 650, - I11. Sup. - .

(14) Where a corporation sued a real estate agent which it had engaged to procure a factory site, on the ground that, despite the fiduciary relations, he made a secret profit, the burden of establishing the fiduciary relations is on the corporation. H. J. Jaeger Co. v. Hannan, 108 A. 1, - N, J. Eq. - .

(15) The burden of proof is upon a broker, suing to recover commissions, to prove that his services were rendered under employment by the principal, or that the latter accepted his agency and his acts, under circumstances showing that he knew the services were being rendered on his account, and while the agent was relying on the principal's obligation to pay for them. Suter v. Farmers' Fertilizer Co., 126 N. E. 304, 100 Ohio, 403.