However, since the original purpose of a non-recourse agreement was to effectively exempt the establishment obligation from the obligation without dismissing the co-obligated parties, many courts have treated an obligation not to bring legal action, as if it were an exemption from the obligation for establishment (with a reservation of rights in respect of non-debtors) and not a future promise, Do not take legal action. In other words, an alliance, not complaining, was like a liberation as a “primary function. To serve as a shield and not a sword.  The reason why an alliance, not to file a complaint, was simply considered a release (but which did not refer to the harsh common law doctrine, which led to such a release to release all debtors, but only to release the debtor in question) was the objective of judicial efficiency. It would be more effective to treat the obligation not to bring legal proceedings as compliance with the obligation of the debtor of establishment vis-à-vis the debtor of establishment and thus simply to dismiss the action brought by the debtor against the debtor of establishment at the same time. Even in situations where a settlement and release agreement included both a declassification obligation and an obligation not to bring legal action, both provisions were generally treated simply as a redundant means of releasing the obligation of the obligated to establish.  Among the many seemingly amphigogic provisions contained in a standard settlement and release agreement are both an unblocking and a separate obligation not to bring an action.