In Kentucky it has been held that a gratuitous new promisee by a surety will not revive his liability.67 On historical grounds a forcible argument may be made for this distinction as to a surety. The obligation of a guarantor was not a debt at common law because he did not receive a quid pro quo.68 And since the consideration required for a new promise which did not have contemporaneous consideration, seems to have been identical with the quid pro quo required for an obligation in debt,69 the previous liability in assumpsit of the guarantor would not furnish sufficient consideration for a subsequent promise. Nevertheless the Kentucky decisions do not seem to have been followed, and in decisions elsewhere no difference is made between new promises by sureties and by others.70 There seems also a certain inconsistency between the Kentucky decisions in question and the numerous cases holding sureties liable on new promises when they have been discharged by a failure to observe some technical requirement necessary to hold them.71