In Tex. Co. v. Davis, 113 Tex. 321, 254 S.W. 304, 308 (Tex. 1923),the lessee abandoned all operations on the lease after the wells it had drilled ceased to produce, and there was no production for about fourteen years. 254 S.W. at 305. There was also evidence that the lessee had expressly released the lease. Id. The Court held the lease had terminated. 254 S.W. at 309. The Court held that reiterating that the implied covenant to explore and produce is not a condition subsequent that would give rise to the lease's termination if breached.