In the case of a speaker making an ironic untruthful statement, the speaker does not propose that the believed-false proposition (e.g., “Brutus is an honorable man”) become common ground (Stokke 2013a, 50). However, in the case of a non-deceptive liar, the speaker does propose that the believed-false proposition (e.g., “I did not cheat”) become common ground (Stokke 2013a, 52). The fact that in the case of a non-deceptive lie it is common knowledge that what the speaker is saying is (believed to be) false does not alter the fact that the speaker is proposing that the believed-falsehood become common ground. Indeed, even if the (believed) truth is initially common ground, before the speaker proposes that the believed-falsehood become common ground, it is still the case that the non-deceptive liar is proposing to “update the common ground with her utterance” (Stokke 2013a, 54). For example, in the case of the student and the dean, “The student wants herself and the Dean to mutually accept that she did not plagiarize” (Stokke 2013a, 54).