"In addition, under contract law, a contract is supported
by consideration even if the consideration flows solely to a
third party. See Mencher v. Weiss, 114 N.E.2d at 181(“[I]t
is fundamental that a benefit flowing to a third person or legal
entity constitutes a sufficient consideration for the promise of
another.”); RESTATEMENT (SECOND) OF CONTRACTS § 71,
cmt. e (1981)."
In re Asia Global Crossing, Ltd.,
326 B.R. 240 (Bankr. S.D.N.Y. 2005)