Eastern Dental Corp. v. Isaac Masel Co.
United States District Court for the Eastern District of Pennsylvania
502 F. Supp. 1354 (1980)
Eastern Dental Corp (EDC) (plaintiff) and Isaac Masel Co. (defendant) conducted a wholesale dental-products relationship for years through invoices and statements alone, with no formal written contract; when Masel terminated the relationship by letter in 1978, EDC sued for breach of an alleged requirements contract, relying on the invoices, the termination letter, and one other letter as sufficient writings to satisfy the statute of frauds. Masel moved for summary judgment, arguing none of these documents adequately established a written requirements contract.
Whether, to satisfy the statute of frauds, there must be some writing indicating that the quantity to be delivered under a contract is a party's requirements or output.