D enters the front seat of P's taxi at the station and says "Take me to the university, please." On arrival at the university, D refuses to pay the fare stating there is no contract because there is no consideration. D, a third-year law student, says the consideration was P driving him to the university. D states that this is past consideration because he is now at the university and that past consideration is no consideration. Issue: Does D have to pay the fee? Rule: For a contract to exist, it must be supported with sufficient consideration. In the case of l:] consideration, if the consideration comes before the C], then the consideration is insufficient: Roscola 4:]- However past consideration can be sufficient if there is an implied E] the past services will be paid for: Check Application