 Fruh (2019) resists this move, and disputes the understanding of oaths as “directed” toward a counterparty. He argues at some length against the plausibility of various candidate counterparties (promisees) for standard oaths. Rather, for Fruh oaths should be understood as a sui generis form of voluntary obligation, different from promises and vows in that it is without a “counterparty”. Liberman (2021) instead argues that oath and vows should be understood as “exceptionless resolutions”, both without counterparty, and both different than traditional promise.