In Meyers v. El Tejon Oil & Refining Co. (1946) 29 Cal.2d 184, a dividend was declared at a special board meeting attended by only four of a corporation's seven directors. (Id. at p. 186.) In contravention of statutory requirements, no notice of the meeting had been given to the directors, and the absent directors did not sign a written consent to the meeting. (Ibid.) Nonetheless, following the declaration of the dividend, all the directors accepted funds derived from the dividend. (Id. at p. 187.) The California Supreme Court held that this conduct constituted ratification of the dividend. (Ibid.) The court rejected a contention that the dividend could be ratified solely by a formal resolution of the board at a duly held meeting, reasoning that "'anything from which it may be clearly found . . . that the board as a board has agreed that the act should be binding will suffice.'" (Id. at pp. 186-187.)