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B. Lewis Productions, Inc. v. Angelou

United States District Court for the Southern District of New York

2005 WL 1138474 (S.D.N.Y. May 12, 2005)

Relevant factsFree

B. Lewis Productions (BLP) (plaintiff) and author Maya Angelou (defendant) signed a letter agreement forming a joint venture in which Angelou would exclusively contribute literary works for BLP to license to greeting card companies, with BLP providing the necessary capital and the parties sharing revenue. The agreement lacked a stated duration and described the works to be used only in general terms. After BLP negotiated a licensing deal with Hallmark, Angelou refused to sign it, terminated the relationship, and later signed her own separate deal with Hallmark. BLP sued for breach of contract and breach of good faith, and Angelou moved for summary judgment, arguing the letter agreement was too vague and indefinite to be an enforceable contract.

IssueFree

Whether a court may supply missing essential terms to complete an agreement if it can do so reasonably and consistently with the parties' intent.

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