In Amedisys, Inc. v. Kingwood Home Health Care, LLC, 437 S.W.3d 507 (Tex. 2014), the Texas Supreme Court analyzed the language of a settlement offer made under Texas Rule of Civil Procedure 167 to determine, inter alia, whether the offer was intended to include claims that had not yet been asserted. In that case, the defendant sent the plaintiff a settlement offer under Rule 167, which stated in relevant part: Please accept this letter as an offer of settlement regarding the above referenced matter. Specifically, my client, Kingwood makes this offer to pay your client, Amedisys to settle all monetary claims between the parties in accordance with Texas Civil Practice & Remedies Code Chapter 42 and Texas Rule of Civil Procedure 167. Kingwood offers to settle with Amedisys the following claims in accordance with Texas Civil Practice & Remedies Code Chapter 42 and Texas Rule of Civil Procedure 167: Kingwood offers a total sum of $90,000 to settle all claims asserted or which could have been asserted by Amedisys against Kingwood in the above referenced case. This full and final offer is for all monetary damages claimed--including attorney's fees, costs and interest that were recoverable as of the date of this offer by Kingwood. A lump-sum payment in the amount of $90,000 will be made by Kingwood within fifteen (15) days after acceptance. If your client agrees, please indicate so by affixing your signature below and returning to me. Id. at 514-15. One of the questions before the Court was whether the defendant's settlement offer was intended to settle all claims between the plaintiff and the defendant, including claims that had not yet been asserted, or whether it was only intended to settle the claims that had been asserted by the parties. Id. at 514-17. After analyzing the language of the settlement offer, the Court concluded that the offer was intended to settle all claims between the plaintiff and the defendant, including claims that had not yet been asserted. Id. at 515. In reaching this conclusion, the Court first noted that the defendant's settlement offer was itself internally inconsistent in its descriptions of the claims that the defendant was offering to settle. Id. It observed that the settlement offer initially offered to settle "'all monetary claims between the parties,'" which omitted any explicit reference to claims that could have been asserted. Id. It then described the claims as "'all claims asserted or which could have been asserted,'" which clearly included claims not yet asserted. Id. But it subsequently stated that "'the offer is for all monetary damages asserted,'" omitting any reference to damages not asserted. Id. Despite these inconsistencies, the Court concluded that, based on the second description of "'all claims asserted or which could have been asserted,'" the settlement offer was intended to settle all claims, including any claims that had not been asserted. Id. In doing so, it interpreted the first and third descriptions ("'claims between the parties'" and "'damages asserted'") as shorthand references to the second description. Id.