Action ex contractu is a personal action that arises out of a contract. Actions ex contractu were somewhat illogically classified as covenant, debt, assumpsit, detinue, and account. The action of covenant lay where the party claimed damages for a breach of contract or promise under seal. The writ of debt was for the recovery of a liquidated or certain sum of money alleged to be due from defendant to plaintiff. The writ of detinue was for the specific recovery of goods, chattels, deeds, or writings detained from the plaintiff.