In Vermont Teddy Bear Co., Inc. v. 538 Madison Realty Co., 1 NY3d 470 (2004) the Court of Appeals stated: When interpreting contracts, we have repeatedly applied the familiar and eminently sensible proposition of law that, when parties set down their agreement in a clear, complete document, their writing should . . . be enforced according to its terms. We have also emphasized the rule's special import in the context of real property transactions, where commercial certainty is of paramount concern, and where the instrument was negotiated between sophisticated, counseled business people negotiating at arm's length.