Alaska Packers’ Association v. Domenico, 117 F. 99 (1902). Facts: Parties: Alaska Packers’, defendant-appellant; Domenico, plaintiff-appellee. Alaska Packers’ hired plaintiffs to do fishing work at a set rate at a certain remote location. Upon arriving at the location, plaintiffs refused to work unless they were given more. Defendant was pressured into agreeing to sign a new contract at a higher rate with plaintiffs. Upon completion of the work, defendants refused to pay and plaintiffs sued. Plaintiffs won; defendants appealed. Issues: Whether work agreed on in one contract constitutes as consideration for a second contract formed solely to modify the first. Rationale: The plaintiffs claimed that they were given defective nets. The court disagreed, stating that for the defendants to do so would violate self-interest. The plaintiffs claimed that the contract signed in the remote location was a new contract. The court disagreed, stating that the plaintiffs already owed the defendants a legal duty (fishing work in a remote location) in the first contract. The court stated that the new contract tried to use the legal duty already owed the plaintiffs as its consideration. The court stated that a new contract formed just for the purpose of modifying the old contract had no consideration if it purported to use a legal duty already owed under the old contract as its consideration. Disposition: The court reversed the decision of the appellate court and remanded the case with judgment for the respondent. Holding: The second contract had no consideration and was thus void because it purported to use a legal duty already owed under the first contract as its consideration. Rule: There is no consideration for a contract created solely to modify an existing contract and whose purported consideration is work done for the first contract.