摘要：Other European law systems do not explicitly rely on the consideration theory. However,
promises of donations need to be contracted in written form under German law also. Loan
guaranties without commercial value to the guarantor are not valid if they are not in written
form. That is why some German scolars think that the consideration doctrine is ¨C in a way ¨C
Europeanised.1 To some extent, this is correct. However, in the mentioned insurance case both
law systems differ essentially. The Europeanisation, therefore, is incomplete.
