In Drye v. Eagle Rock Ranch, Inc., 364 S.W.2d 196 (Tex. 1962), purchasers of lots in a failed subdivision sought declaratory judgment establishing easements for pleasure and recreation across an adjacent ranch owned by the seller's alter ego. Drye, 364 S.W.2d at 198-201. The court considered whether the purchasers acquired rights by private dedication, by implied easements appurtenant, or by estoppel. Id. at 203-11. The court rejected the purchasers' argument regarding the creation of an easement by implication because the recreational easement was not necessary to the use of the dominant estate. Id. at 208. The court then considered whether estoppel in pais should apply. Id. at 209. The court noted that easement by estoppel usually arises in cases concerning the dedication of a street. Id. According to Drye, the doctrine has been used in situations in which the owner sells land with reference to a map or plat on which streets are depicted. Id. at 210. When a purchaser, acting in reliance on the representations, "buys with reference thereto and spends money to make improvements, the seller will not be heard to say that such easements do not exist." Id. The Drye court found the particular easement in that case to have been too indefinite to be enforceable. Id. at 211.