The court may issue an order of the „specific benefit“ that requires the performance of the contract. In certain circumstances, a court will order a party to keep its promise (a „specific benefit order“) or to issue an injunction known as an „injunction of omission“ that a party will refrain from doing something that would be contrary to the treaty. Some benefit is available for breach of a contract to sell land or real estate with reasons such that the property has a unique value. In the United States, through the 13th Amendment to the U.S. Constitution, the specific provision in personal service contracts is only legal, „as punishment for a crime whose criminal must be wrongly convicted.“  An exception arises when advertising makes a unilateral promise, such as offering a reward, as decided in the famous case of Carlill v Carbolic Smoke Ball Co, in 19th century England. The company, a pharmaceutical manufacturer, proposed a smokeball that, if it sniffed „three times a day for two weeks,“ would prevent users from catching the „flu.“ If the smokeball does not prevent „the flu, the company promised that it would pay $100 to the user, adding that they deposited „$1000 in the Alliance bank to show our sincerity in the file.“ When Ms. Carlill complained about the money, the company argued that the complaint should not be considered a serious and legally binding offer; instead, it was a „simple mess“; However, the Court of Appeal found that Carbolic had made a serious offer to a reasonable man and found that the reward was a contractual undertaking. If the contract does not comply with the legal requirements that are considered a valid contract, the law does not enforce the contractual agreement and the aggrieved party is not obliged to compensate the non-infringing party. In other words, the plaintiff (a non-dented party) in a contractual dispute suing the criminal party can only obtain reimbursement of the damages-expectations if he is able to prove that the alleged contract was in place and that it was a valid and enforceable contract.