A contract in which the promisor engages to the promisee to render some performance to a third person is generally called a contract for the benefit of a third person with little regard to whether the purpose of the promisee in entering into the contract was his own benefit or the benefit of the person to whom performance was to be rendered. The inherent difficulty of correctly determining the legal rights under such contracts is shown both by the varying attempts at theoretical analysis and the contradictory results reached by the decisions. The intrinsic difficulty of the problem is also shown by the fact that in the Roman Law and the Modern Civil Law, as well as in English and American Law, the questions involved have been a source of trouble and confusion.1 Any attempt to clear up the confusion must be based in the first place on an understanding and differentiation of several varying types of cases in which third persons may be interested in agreements made between contracting parties.