 Gideon Rosen suggests an alternative conceptual framework for the debate between textualists and contextualists, one that deemphasizes the parties’ semantic intentions. Following Grice (1957), we can distinguish the parties’ semantic intentions in relation to their speech acts (intentions to mean this or that by one’s words) from their pragmatic and distinctly legal intentions (the intent to cause legal effects via one’s speech acts, like the creation of a judicially enforceable promise). The parties’ legal intentions—which seem to matter, ultimately—can come apart from their semantic intentions. In re Soper’s Estate (1935) offers an illustration. In that case, the deceased designated his “wife” as the beneficiary of his estate. However, Soper was legally married to person 1, faked his own death, and then “married” person 2. We can set aside what “wife” objectively means in this context. We can also stipulate that Soper’s legal intention was to leave his estate to person 2. Suppose Soper’s semantic intention was to refer to 2 under the description my wife in the legal sense on the erroneous assumption that his prior marriage to 1 was not a legal impediment. Clearly, the semantic intention to refer to 2 as his legally recognized wife would have been irrelevant to what Soper was trying to accomplish legally by writing his will. We can, of course, construct alternative scenarios where the semantic intention is relevant to Soper’s legal intent. Indeed, contract law’s interest in semantic intentions is explained by the fact that, in general, what we intend to mean by our words bears on what we are trying to accomplish legally. But In re Soper’s Estate illustrates that the connection is contingent—the alignment that usually exists between the legal effects that we intend to produce and the descriptions under which we intend to produce them is far from guaranteed.