Open sandwiches are sandwiches that are made with only a single slice of bread. It has given rise to some controversy in the philosophy of language study of meaning underdetermination after a judge had to consider whether a burrito was a sandwich for the purposes of enforcing an exclusive use clause in an American legal case. The judge followed the definition of "Merriam Webster's Dictionary": "two thin pieces of bread, usually buttered, with a thin layer (as of meat, cheese or savory mixture) spread between them". Because the burrito was "typically made with a single tortilla", the judge said it was not a sandwich.