In some states a promise under seal is binding without consideration.

Name: In some states a promise under seal is binding without consideration.
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In some states, a promise under seal is considered a legally binding contract regardless of whether there was any consideration exchanged. This is referred to as a "sealed instrument" or a "contract under seal." However, the use of sealed instruments has largely been replaced by other forms of contracts that require consideration to be legally enforceable.

In Some States a Promise Under Seal Is Binding Without