In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Co., 633 F.2d 214 (table) 1980 LEXIS 13583 (6th Cir.1980) (quoting C.J.S. Contracts 100(1) at pp. 790-91); Willard, Sutherland & Co. v. United States, 262 U.S. 489, 43 S.Ct. 592, 67 L.Ed. 1086 (1923); General Motors Corp. v. Keener Motors, Inc., 194 F.2d 669 (6th Cir.1952); Tennessee Enamel Mfg. Co. v. Stoves, Inc., 192 F.2d 863 (6th Cir.1951). "A promise that does not put any limitation on the freedom of the alleged promissor but leaves his future action subject only to his own will is illusory. It is not enforceable against the one making it nor operative as consideration for a return promise." Pippin Way v. Four Star Music Co. (In re Four Star Music Co.), 2 B.R. 454, 460 (Bankr.M.B.Tenn.1979); Loudenback Fertilizer Co. v. Tennessee Phosphate Co., 121 F. 298, 302 (6th Cir.1903) (<HOLDING>). A distribution agreement that does not
Holding statements: (A) holding that the right of action accrued upon failure to perform contract (B) holding that mutuality of obligation is essential for contracts based on mutual promises and that a contract is unenforceable where a party is free to perform or not perform the contract (C) holding mutuality of obligation is essential to the formation of a bilateral contract (D) holding that a contract need not have mutuality of obligation as long as it is supported by consideration (E) holding that a contract without a minimum quantity term is unenforceable for lack of consideration and mutuality
holding that the right of action accrued upon failure to perform contract