| Buri |
Anyone can make a word/letter substitution cypher for another language that "reads" like its own. But, to create your own from scratch isn't easy. Languages are complex and often evolve over dozens and hundreds of generations and are constantly evolving. I'd make it a high DC to do so. Probably 40 or so although the source languages would matter. Probably drop that to just 20 if it were based on common. 30 if dwarven or some such. 40 if based on draconic with smatterings of other things.
Lincoln Hills
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I suppose a band of adventurers who all had two or more languages in common could create a 'pidgin' that outsiders would need a Linguistics check to decipher - for example, employing Elven syntax and a mixture of Common, Goblin and a few deliberate cod words. It seems like a lot of work for not much payoff, though. Everybody picking up a very, very obscure language (Gith was my standby in the days of Third Edition) is probably better.