 The leading decision involving pre-existing contractual obligation owed to the same party is the case of Gilbert Steele and University Construction, which is a decision of the Ontario Court of Appeal. In that case, we have two agreements, and they both involve the same parties. One party, the first party, which is the plaintiff, is Gilbert Steele, and the second party is University Construction. Gilbert Steele was a supplier of Steele for construction, and University Construction was the general contractor. So agreement number one between these two parties involved a promise by University Construction to pay a set price for the supply of Steele by Gilbert Steele. So Gilbert Steele had promised to supply several shipments of Steele at that set price. Now as after a few shipments had been made, the world price of Steele had gone up. So Gilbert Steele went back to University Construction and told them about the increase in the price of Steele to see if University Construction would be willing to pay a higher price for the remaining shipments of Steele. So that led to agreement number two between Gilbert Steele and University Construction. Under agreement number two, University Construction had agreed to pay an additional amount for the Steele, and that additional amount was for Gilbert Steele to supply the remaining shipments as per the original agreement number one. The court found that that promise to supply the remaining shipments under agreement number two was not valid consideration because that promise had already been made under agreement number one, and that University Construction did not receive any new benefit from that promise to supply the remaining shipments, and therefore that second contract, agreement number two, is void for lack of consideration.