it is still efficient to hold companies liable that produce greater wealth. In the real world, where people cannot negotiate costlessly, there may be collective action problems of those who caused a nuisance, for instance by smoke emissions from a factory to many neighbouring farms, and so getting together to negotiate effectively can be difficult against a single polluter because of coordination problems. If it is efficient for the farmers to pay the factory to reduce its emissions, some of those farmers may hold off paying their fair share, hoping to get a free ride. The factory may be in a better position to know what measures to take to reduce harm, and can be the cheapest avoider, illustrating Coase's argument. Cases and statutes Coase uses three main examples in his article to attempt to illustrate his points. The first is a fictional cattle herder and a farmer, but the second is the case Sturges v Bridgman and the third is the Railway (Fires) Act 1905. Apart from these main examples, the following cases are referred to. Fontainebleu Hotel Corp. v. Forty-Five Twenty-Five, Inc., 114 So. 2d 357 (1959) Cooke v Forbes (1867–1868) LR 5 Eq 166 Bryant v Lefever (1878–1879) 4 CPD 172, Bramwell LJ and Cotton LJ Bass v Gregory (1890) 25 QBD 481 Attorney General v Doughty (1752) 28 ER 290 Versailles Borough v. McKeesport Coal & Coke Co. (1935) 83 Pitts. Leg. J 379, 385 Webb v Bird (1863) 143 ER 332 Rushmer v Polsue and Alfieri, Ltd (1906) 1 Ch 234 Adams v Ursell (1913) 1 Ch 269, regarding fish and chips Andreae v Selfridge and Company Ltd (1938) 1 Ch 1 Delta Air Corporation v. Kersey (1942) 193 Ga. 862 Thrasher v. City of Atlanta (1934) 178 Ga. 514 Georgia Railroad and Banking Co. v. Maddox (1902) 116 Ga. 64 Smith v. New England Aircraft Co. (1930) 270 Mass. 511 Vaughan v Taff Vale Railway Co. (1858) 3 H and N 743 Boulston v Hardy (1597) 77 ER 216 Stearn v Prentice Bros Ltd (1919) 1 KB 395 Bland v Yates (1913–1914) 58 Sol J 612 See also Theory of the firm Notes References . RH Coase, 'The Nature of the Firm' (1937) 16(4) Economica 386–405 Sir Alfred Denning, Freedom Under the Law (1949) 71 E McGaughey, 'Behavioural Economics and Labour Law' (2014) LSE Legal Studies Working Paper No. 20/2014 AC Pigou, The Economics