Lord Atkin used the concept of legal neighbours in an address to the University of Birmingham's Holdsworth Club on 9 May 1930, in which he commented that "the man who swears unto his neighbour and disappointeth him not is a person commended by the law of morality, and the Law enforces that by an action for breach of contract". On 28 October 1931, just over one month before he heard "Donoghue", Lord Atkin also used the principle in relation to defamation, perjury, fraud and negligence in a lecture at King's College London.