Migerobe, Inc. v. Certina USA, Inc.

Migerobe (plaintiff) negotiated with Certina salesman Gerald Murff to buy over 2,000 watches at a special discounted price, an arrangement documented across three separate internal Certina (defendant) records: a signed memo from Certina's vice president authorizing Murff to sell at the special price, a signed memo announcing a promotion code covering the special Migerobe order, and an unsigned order form listing the specific quantities, styles, and prices ordered. When Certina's national accounts manager later refused to ship the watches, Migerobe sued for repudiation, and a jury found for Migerobe and awarded damages; Certina appealed, arguing no single writing satisfied the statute of frauds.