The Delaware Chancery Court Cites MSCD on “The Expectation of Relevance”

In its recent opinion in Salama v. Simon, No. 2024-1124-JTL, 2024 WL 4906737 (Del. Ch. Nov. 27, 2024), the Delaware Court of Chancery cites A Manual of Style for Contract Drafting for what it has to say about “the expectation of relevance.” That’s a concept underlying a subtle ambiguity associated with the word may.

Rather than discuss the expectation of relevance here, I’ll be lazy and point you to the court’s opinion. Just search for “Adams”.

The opinion is by Vice Chancellor Laster. He’s no stranger to MSCD, as he wrote a foreword to the fourth edition; I’ve preserved it in the fifth edition. You can read it here.

About the author

Ken Adams is the leading authority on how to say clearly whatever you want to say in a contract. He’s author of A Manual of Style for Contract Drafting, and he offers online and in-person training around the world. He’s also chief content officer of LegalSifter, Inc., a company that combines artificial intelligence and expertise to assist with review of contracts.

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