Article

Does an Email Satisfy the Statute of Frauds?

The Seventh Circuit holds that emails, sent by a manufacturer's employee to a supplier, referencing quantities of goods greater than those listed on the relevant purchase orders but consistent with the supplier's order acknowledgment satisfied the statute of frauds. In support of its ruling, the Seventh Circuit also noted the existence of a notation by another employee referencing the increased order. The Court reasoned that the sender's name on the email satisfied the signature requirement of the statute of frauds. Cloud Corp. v. Hasbro, Inc., 314 F.3d 289 (7th Cir. 2002).