of the parties is a broadening and still less developed area of the law which continues to present challenges for the courts today. Politicians, state legislatures, and courts grapple with a multitude of legal issues surrounding families created using fertility treatments in view of divergent moral, political, and legal discourse throughout the United States. For example, in Illinois, the courts employ at least two clear approaches to determining how embryos are allocated in the event of a divorce or separation of the parties. Specifically, the courts seek to enforce any contractual language surrounding the allocation of the embryos, and they also employ a balancing test of the parties’ interests alongside the contractual approach or simply as an alternative approach if no contract exists. State courts are often left to decide these issues as statutory resources are not well-developed across the states. For example, in Illinois, the Illinois Parentage Act of 2015 has contemplated situations in which parties, represented by independent legal counsel, enter into contractual agreements regarding the allocation of embryos, but no uniform statutory answer exists for situations in which parties failed to enter into such written agreements regarding allocation. References Assisted reproductive technology Cryopreservation