There is no privity of contract between a surety and the principal debtor. Such liability may be imposed even without privity of contract. This risk of auditors' liability to third parties is limited by the doctrine of privity. However, in general, the assignee has privity of estate with a lessor. Certain elements of the doctrine of agency have been said to clash with privity, however. Trusts have been used as a way around the original doctrine of privity. It seems to be in line with the "privity of contract" doctrine. A requirement of privity, not of contract but of relationship, was laid down. The courts however decided that there was no privity of contract between manufacturer and consumer. In such cases, the privity letter establishes a duty of care. There is no privity of contract between the manufacturer and the consumer. A general consensus is that privity is distinct from consideration. The "near privity" approach was established in "Credit Alliance Corp. v. Arthur Andersen & Company". This method is very liberal and broad in terms of scope, unlike the privity approach. Privity of Contract played a key role in the development of negligence as well.