"It should not be assumed that a similarity between terms ('active' vs. 'actively at work') will lead a court to conclude that the same meaning is intended for each, or that one is intended to explain the meaning of the other. Instead, it's just as likely that the court will consider undefined terms to be ambiguous and construe them against the drafter." [Carlile v. Reliance Standard Life Ins. Co., Nos. 19-4123, 20-4005 (10th Cir. Feb. 22, 2021)]