 Even in this case, the central challenge facing the various strains of pluralism remains in place: that of explaining how law integrates its several and often competing normative commitments. To what extent are decisions informed by some “covering value”, in Ruth Chang’s (2004) terminology, or synthesizing principles? A recent proposal suggests an organizing principle based on a typology of contracts and contracting parties (Leib 2005). Wealth maximization may be appropriate in the enforcement of contracts between firms, for example, whereas promissory virtue becomes a more significant object of concern in contractual disputes between natural persons (see also C. Riley 2000). Along similar lines, Dagan and Heller (2017) suggest that distinct contract-types implicate distinct values, and that the organizing principle that determines which normative structure applies is the choice principle—the parties’ freedom to choose the rules that govern their exchange relations. Such proposals sit uncomfortably with existing law, which does not explicitly distinguish the application of its basic doctrines in this way, even if it should.