The most recent case of Hole v Hole, 2016 ABCA 34, poses a problem with regard to the application of a contract between family members. In this case, the applicant, James F. Hole, is the owner of the complainant, Hole Consultants Ltd. Respondents own the companies surveyed as follows: James D. Hole owns Hole Engineering Ltd; Jack Hole owns Kessa Holdings Ltd. Harry Hole owns Eloh Enterprises Ltd. and Douglas Hole owns 512725 Alberta Ltd. The individual applicant and each respondent are members of the same family. Jack Hole and Douglas Hole are the sons of each of the plaintiffs, while James D. Hole and Harry Hole are the brother and nephew of each of the plaintiffs, respectively. If two or more parties reach an agreement without written documentation, they draw up an oral agreement (formally called an oral contract). In the absence of one or more elements of a valid contract in an oral contract, it is likely that a court will annul the agreement and it will not be enforceable. Many states have rules for certain treaties that need to be written, which believes that oral agreements are insufficient.