 Another set of theories emphasizes the formal structure of the legal relation of contract itself, even apart from any commercial or social relationships within which it arises (Markovits 2004; Bensen 2019). The doctrines governing offer and acceptance require contractual promisors to form (and to communicate) intentions that refer to their promisees. The parties to contracts, that is, intend to pursue ends that do not merely coincide but rather, to borrow a formulation from David Hume, “have a reference to” each other (A Treatise of Human Nature, L.A. III, 2, ii.). Moreover, each promisor intends not simply to do things but to be bound to do things, entrenching her deference to the promisee, intending to perform unless released. Her obligation endures at his option, so that she gives him power over her normative situation. Contracts, that is, establish the transaction as a normative unit.