No-Strike Clauses in the Federal Courts

One consideration will support several promises. A promisor may extract more than one promise in return for his single undertaking to do – or not to do. It depends upon his bargaining power. His single undertaking may be so valuable that several promises are necessary to induce him to act, or not to act. He is privileged to hold out for the best deal. The law does not examine his motives or reduce his demands. And from this arises the common- law principle that one consideration may support several promises.