Fairmount Glass Works v. Crunden-Martin Woodenware Co.
Court of Appeals of Kentucky
51 S.W. 196 (1899)
Crunden-Martin Woodenware Co. (plaintiff) asked Fairmount Glass Works (defendant) for its lowest price on ten carloads of Mason jars. Fairmount replied with a letter labeled a "quote," inviting "immediate acceptance." The next day, Crunden-Martin telegrammed to place the order on those exact terms; that same day, Fairmount responded that it could not fill the order. Crunden-Martin sued for breach, arguing its telegram had formed a binding contract; Fairmount argued its letter was a mere price quotation, not an offer, so nothing bound it. The trial court ruled for Crunden-Martin.
Whether a party's price quote that invites the recipient's acceptance becomes a binding offer that cannot be revoked once the recipient accepts it.