A promise of a future performance can create a valid if all of the other common law requirements are met, but can never create a valid . Unlike contracts, both parties to a gift do not need to provide . If Oprah promises to give a friend a car next week as appreciation for all the good things the friend has done in her life, Oprah's statement is , either as a contract or a gift. If Oprah gives her friend a car and the certificate of title today, but asks the friend to wait until next week, when Oprah will be visiting, to drive it for the first time, Oprah has made a gift, which is .