(or "fly-out") menus are more likely to be used for setting a value, and might appear anywhere in a window.

According to traditional human interface guidelines, menu names were always supposed to be verbs, such as "file", "edit" and so on. This has been largely ignored in subsequent user interface developments. A single-word verb however is sometimes unclear, and so as to allow for multiple word menu names, the idea of a vertical menu was invented, as seen in NeXTSTEP.