 The leading decision on pre-existing contractual obligations owed to a third party is the case of Pao An and Lao Yi Long, or I call it the Food Chip Case, because it involves a corporation by that name. The plaintiff in the Food Chip Case had entered into an agreement with Food Chip Corp for the purchase of shares, so the consideration exchange there was that Food Chip shares would be sold by the corporation to the plaintiff in exchange for the payment of a certain price for the shares and also a promise not to resell those shares or not to resell more than 60% of those shares within within a year. Now another agreement that the plaintiff entered into was an indemnification agreement with the majority shareholders of Food Chip Corp. So this is the agreement that that was called into question as to whether or not it was a valid contract. Under that indemnification agreement, the majority shareholders of the defendants had promised to indemnify for any losses that the plaintiff may suffer. So if the price of those shares had gone down below a certain level, the majority shareholders would have compensated the plaintiff for that loss under that promise. In exchange for that promise, the consideration provided by the plaintiff to the majority shareholders was a promise not to resell more than 60% of the shares within the year. So it was the exact same promise that the plaintiff had made to Food Chip Corp under the other agreement, the agreement for the purchase of the shares. So the issue was now is that promise to not, so not to resell more than 60% within a year made to the majority shareholders is that considered to be valid consideration because it was a preexisting contractual obligation that the plaintiff already had to someone else, which was the corporation. And the court there found that that that promise was valid consideration, that this previous promise is a new benefit for the majority shareholders under the indemnification agreement and therefore it is valid consideration.