Parties sometimes draft their own contracts. If it is a simple transaction or deal, or if they have a go-by to use, they might think, “Why not?” This can lead to some serious problems, not the least of which is that the contract does not state what the parties agreed to. I see this sometimes in my litigation practice. A client might ask us to demand that the other party do such and such. After reviewing the contract, we learn that the contract does not require the other party to do such and such. This problem can arise even in complex contracts drafted by lawyers and involving sophisticated business parties. A recent case out of the Fourth Circuit Court of Appeals reminds us of this pitfall.