I saw a recent quote by Mark Cooney, an Associate Professor at The Thomas M. Cooley Law School that dealt with the use of plain language. It brought to mind an article entitled "Legalese and the Myth of Case Precedent" of which I was one of the authors. It appeared in the October 1985 edition of the Michigan Bar Journal. It examined the use of “legalese” in an Offer to Purchase Real Estate and argued for the use of plain language. Mr. Cooney said: "The utilization of inflated language characterized by exceptional verbosity is not the most efficacious methodology for accomplishing the communication of sophisticated ideas. To sound smart, make it simple."