Is a failure to perform services justified a breach of a contract?

'While the California cases have never expressly held that a presumption in favor of bilateral contracts exists, the cases clearly indicate a tendency to treat offers as offers of bilateral rather than of unilateral contracts.' (Davis v. Jacoby, 1 Cal.2d 370, 379, 34 P.2d 1026, 1030.)

The acceptance of an offer to pay for services to be performed by the offeree obligates the latter to perform the services, without an express promise on his part to do so. (Meyers v. Nolan, 18 Cal.App.2d 319, 323, 63 P.2d 1216.)

'By accepting defendant's proposition plaintiff's assignors bound themselves to render the services called for, thereby establishing a sufficient consideration.' (Meyers v. Nolan, 18 Cal.App.2d 319, 323, 63 P.2d 1216, 1217.)

The performance of such services by the promisee fixes the obligation of the promisor and furnishes consideration therefor. (Yaguda v. Motion Picture Publications, Inc., 140 Cal.App. 195, 35 P.2d 162.)

IS THE FAILURE TO PERFORM SERVICES A MATERIAL BREACH JUSTIFYING RESCISSION?