(In Goonewardene v. ADP, LLC (2019) 6 Cal.5th 817, the Supreme Court held that a non-party to a contract make invoke it as a third party beneficiary only if it established all three of the following: (1) it would in fact benefit from performance of the contract, (2) providing that benefit to it was a motivating purpose of the parties in entering into the contract, and (3) allowing it to sue would be consistent with the objectives of the contract and the reasonable expectations of the contracting parties. Those three factors may be shown or disproven by the contract’s terms and by surrounding circumstances. Here, Oakland showed that it benefited from the NFL’s relocation policy and that one purpose of that policy was to benefit the cities in which NFL teams were located. So Oakland satisfied the first two factors, but fell short on the third. Giving host cities the right to sue would be inconsistent with the fact that the relocation policy expressly leaves relocation decisions up to the teams to decide in their best economic interest. Indeed, the policy was adopted precisely to avoid government intervention and to retain control over relocation decisions.)