This chapter examines reference in a non-collaborative context. Despite the collaborative nature of referring, there are times when referring become problematic. Focussing specifically on problems in referring, we explore some of the reasons for problematic reference, including how the problems get resolved. The main focus of the chapter is on uses of reference in contexts which are discursively non-collaborative, despite shared common ground. This chapter makes a significant contribution by detailing how referring works when the speaker and addressee do not share goals and have no invested interest in a shared conceptualisation of the referent. We look at various examples from primarily legal contexts to extend our understanding of reference in these contexts. We show that collaboration is indeed needed even when the social relationship is adversarial but that the strategies for ratifying an expression differ depending on whether or not speaker and addressee share the same discourse goals.