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Cloud Corp. v. Hasbro: Difference between revisions

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{{Infobox Case Brief
{{Infobox Case Brief
|court=United States Court of Appeals for the Seventh Circuit
|court=United States Court of Appeals for the Seventh Circuit
|date=December 26, 2002
|date=2002-12-26
|subject=Property
|subject=Contracts
|case_treatment=No
|facts=Cloud Corporation ("Cloud") & [https://corporate.hasbro.com/en-us Hasbro Incorporated] engage in casual communications in the form of e-mail.
|facts=[https://cloudcorp.net/ Cloud Corporation] & [https://corporate.hasbro.com/en-us Habro Incorporated] engage in casual communications in the form of e-mail.
 
Hasbro, a toymaker, engaged with "Cloud" to produce powder packets for aquariums.
 
Hasbro would transmit purchase orders to Cloud via e-mail; Cloud would reply to confirm the order.
 
Over time, the popularity of the toy aquariums waned; Hasbro sent Cloud an 8.4 million order packet.
 
After several intermediate occurrences, Hasbro refused to accept a Cloud delivery for 9.5 million powder packets.
|procedural_history=Cloud sued for breach of contract; Hasbro wins in the trial court.
 
Cloud appealed to the [https://www.ca7.uscourts.gov/ 7th Circuit].
|issues=Can informal e-mails create a contract modification that satisfies UCC's statute of frauds?
|holding=Yes. A modification to a contract via e-mail bearing the sender's name can satisfy the UCC's statute of frauds.
|rule=The [https://www.law.cornell.edu/ucc Uniform Commercial Code] (UCC)'s statute of frauds requires sales of goods over $500 (last figure based on inflation) to be signed.
|rule=The [https://www.law.cornell.edu/ucc Uniform Commercial Code] (UCC)'s statute of frauds requires sales of goods over $500 (last figure based on inflation) to be signed.
|case_text_links={{Infobox Case Brief/Case Text Link
|case_text_links={{Infobox Case Brief/Case Text Link
|link=https://www.quimbee.com/cases/cloud-corp-v-hasbro-inc
|link=https://www.quimbee.com/cases/cloud-corp-v-hasbro-inc
|case_text_source=Quimbee video summary
|source_type=Video summary
|case_text_source=Quimbee
}}{{Infobox Case Brief/Case Text Link
}}{{Infobox Case Brief/Case Text Link
|link=https://casetext.com/case/cloud-corp-v-hasbro-inc
|link=https://casetext.com/case/cloud-corp-v-hasbro-inc

Latest revision as of 03:42, July 14, 2023

Cloud Corp. v. Hasbro
Court United States Court of Appeals for the Seventh Circuit
Citation
Date decided 2002-12-26

Facts

Cloud Corporation ("Cloud") & Hasbro Incorporated engage in casual communications in the form of e-mail.

Hasbro, a toymaker, engaged with "Cloud" to produce powder packets for aquariums.

Hasbro would transmit purchase orders to Cloud via e-mail; Cloud would reply to confirm the order.

Over time, the popularity of the toy aquariums waned; Hasbro sent Cloud an 8.4 million order packet.

After several intermediate occurrences, Hasbro refused to accept a Cloud delivery for 9.5 million powder packets.

Procedural History

Cloud sued for breach of contract; Hasbro wins in the trial court.

Cloud appealed to the 7th Circuit.

Issues

Can informal e-mails create a contract modification that satisfies UCC's statute of frauds?

Holding

Yes. A modification to a contract via e-mail bearing the sender's name can satisfy the UCC's statute of frauds.

Rule

The Uniform Commercial Code (UCC)'s statute of frauds requires sales of goods over $500 (last figure based on inflation) to be signed.

Case Text Links