 Finally, the harm-based view conceives of promissory duties as arising only when the promisee reasonably relied or formed reasonable expectations. This invites the question of what might ground the reasonableness of reliance or expectations. The answer cannot be that the promisor is obligated by her promise and it is reasonable for the promisee to expect the promisor to honor her obligations. As an account of promissory obligation, this argument travels a (very short) circle. The theoretical problem, moreover, is directly captured in law, given the contrast between contract and the misrepresentation torts. These torts include, among their elements, that defendants must have failed to exercise reasonable care in making false statements and, additionally, require plaintiffs to have justifiably relied on defendants’ false statements (Restatement (Second) of Torts §552). Moreover, tort law expressly adds that a party asserting liability for misrepresentations must have relied specifically on the representations’ being true, rather than just “upon the expectation that the maker [of the false statement] will be held liable in damages for its falsity” (§548). Contract takes the opposite approach. As Learned Hand observed in discussing warranties: