Dynamic Machine Works, Inc. v. Machine & Electrical Consultants, Inc.

After a SARS-related production delay in Taiwan, Dynamic (plaintiff, styled as buyer) and Machine (defendant, styled as seller) extended the deadline for commissioning a lathe, and Dynamic's president later sent a signed letter "granting" Machine a further extension to December 19, 2003, using terms Dynamic later argued reflected a unilaterally revocable waiver rather than a bilaterally agreed modification; when Dynamic sought to retract that extension and refuse delivery altogether, the district court certified to the state's highest court the question of whether a buyer may unilaterally retract such a written extension absent the seller's reliance on it.