An attempt is often made to distinguish new promises which fall within the statute from those falling outside its limits by saying that where the new promisor makes the debt his own, the promise is not within the statute. The difficulty with this definition is that it is liable to be misunderstood. If it is taken to mean that wherever the new promisor undertakes for any valid consideration to pay the debt, it becomes his and his promise is not within the statute, the rule is not supported by the cases, for it is at least requisite that the promisor must receive a consideration beneficial to himself in order to make an oral promise by him binding, and it will in the next sections be argued that it is also necessary that the consideration must be received as the equivalent of the promised debt, not as the equivalent merely of the risk the promisor may run of losing his money if the primary debtor cannot be compelled to fulfil his obligation. The emphasis, therefore, in stating the maxim must be laid on the word "debt" becoming his own as distinguished from a liability being incurred under a special it was that the parties were in fact dealing about. What was the subject-matter of the contract? If the subject-matter of the contract was the purchase of property - the relief of property from a liability, the getting rid of incumbrances, the securing greater diligence in the performance of the duty of a factor, or the introduction of business into a stockbroker's office - in all those oases there was a larger matter which was the object of the contract. That being the object of the contract, the mere fact that as an incident to it - not as the immediate object, but indirectly - the debt of another to a third person will be paid, does not bring the case within the section. This definition or rule for ascertaining the kind of cases outside the section covers both 'property cases,' and 'del credere cases.' ... It was suggested that the true definition of cases which do not come within s. 4 should be, not those in which the obligation to pay the debt of another is an incident of a larger contract, but those in which the main object is to secure the promisor's own personal interest. But, I think, if such a definition were adopted, there would be nothing left to come within s. 4, because in every case there must be a consideration for which the promisor bargains to come to him from the promisee. That is as true of mere forbearance as of anything else." It is to be observed, however, as a commentary on the attempt made in the above extract to bring the "property cases" within the scope of the suggested rule, that in those cases the one and only object of the creditor who transfers the property is to get his debt paid; and the new promisor agrees to that object, but he agrees to do it in order to get the consideration which he wants, just as does every surety or guarpromise. Even if the statement is made in this form, however, it is open to possible misconstruction; for if it is taken to mean that the obligation must become exclusively that of the new promisor as distinguished from that of the original obligor, the cases are opposed to the rule. It is not requisite that the new promise shall be taken in discharge of the old indebtedness.23 If, however, the meaning of the rule is understood to be that the new promisor must have become either (1) the sole debtor or (2) the principal debtor as between himself and the original debtor, or (3) that the creditor must be justified in so assuming, the rule is identical in substance with the less ambiguously stated rule, the correctness of which is hereafter urged.24