对价,亦即约因(consideration),作为英美契约法中一项非常重要的制度,有其浓厚的法律文化背景并经历了漫长的历史沉淀过程,通过法官的司法判例确立了一系列特色鲜明的原则。合同法在各国社会生活中都占有很重要的地位,尤其是在商品经济社会中,合同制度的存在有效的保障了社会的经济秩序。所以对正处于改革开放深入发展的我国,了解别国的合同法律制度,尤其是与我国的合同法存在着显著不同的国家的合同法律制度尤为重要。 Consideration, or consideration, as a very important system in the Anglo-American contract law, has its own strong legal and cultural background and has undergone a long history of settling down. Judicial jurisprudence has established a series of distinctive features in principle. Contract law occupies a very important position in the social life of all countries, especially in a commodity-economy society. The existence of the contract system effectively guarantees the social economic order. Therefore, it is particularly important for our country, which is in the deep development of reform and opening up, to understand the contract law system of other countries, especially the contract law system that is significantly different from the contract law of our country.