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Contracts can involve more than just two parties, with third party beneficiaries benefiting from a contract's performance. American courts have recognized the rights of third party beneficiaries since 1806. In the case of Lawrence V Fox, the court found that Lawrence was an intended third party beneficiary with legal rights to enforce the contract. A third party beneficiary can be a donee or creditor, with a donee benefiting from a contract without providing a service in exchange.