The promisee can also sue the promisor for failing to pay the third party beneficiary. In unilateral contracts, the promisor seeks acceptance by performance from the promisee. Past consideration is consideration that has already flowed from the promisee to the promisor. The promisor had maximum protection and the promisee had maximum risk in this scenario. Section 4 preserves the right of the promisee to enforce any term of the contract. This was because the consideration for the contract was the performance of the promisee. Promises can be valuable to the promisee or even to the promiser. Therefore, consideration from the promisee was indulgent of the claim. The person to whom the manifestation is addressed is the Promisee.