| 1. | The person to whom the manifestation is addressed is the Promisee.
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| 2. | Promises can be valuable to the promisee or even to the promiser.
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| 3. | In unilateral contracts, the promisor seeks acceptance by performance from the promisee.
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| 4. | This is because the consideration for the contract was the performance of the promisee.
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| 5. | The promisor has maximum protection and the promisee has maximum risk in this scenario.
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| 6. | An option contract can provide some security to the promisee in the above scenario.
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| 7. | Basically, the consideration is provided by the promisee's beginning of performance.
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| 8. | The court also established the principle that " consideration must flow from the promisee ."
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| 9. | Therefore, the only reliance that the promisee must demonstrate is the actual making of the part payment.
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| 10. | This may seem unfair, but it is up to the promisee whether or not he enforces the promise.
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