In Bendell v. De Dominicis, 251 NY 305 [1929] plaintiff "was a duly licensed broker when he was first employed [in 1926] and also when the contract of sale ... was entered into on November 15, 1927" (251 NY at 307). He was unlicensed, however, from September 30, 1926 to November 7, 1927 (id.), and he apparently performed the relevant services during that period (id. at 309). The Court held that he was not entitled to a commission because he was unlicensed during that time (id. at 311 ["Illegality is a defense to the action.... Otherwise an unlicensed broker might negotiate sales with impunity up to the point of a complete agreement and then obtain his license for the purpose of recovering his commissions on the execution of a formal contract. The law is not so toothless."]).