  Some firms have charitable programs that seem to be cases of pure beneficence—that is, not ones admixed with forms of outreach that will help the company. Money is taken directly out of profits, with no expected return of benefits. It has been questioned, however, whether programs of even this description are instances of pure benevolence. In the precedent U. S. case of A. P. Smith Manufacturing v. Barlow (1953), a judge determined that a beneficent charitable donation to Princeton University by the A. P. Smith Co. was a legitimate act of beneficence by responsible corporate officers. However, the judge acknowledged that such beneficence may not be pure beneficence, but rather an act taken in the interest of the corporation by building its public image and esteem. In effect, the judge suggests that such a gift, while beneficent, may not derive from entirely benevolent motives. If beneficent acts by corporations are nothing more than clever ways to maximize profits, then these actions seem to satisfy Friedman’s conception.