Nordyne, Inc. v. International Controls & Measurements Corp.
United States Court of Appeals for the Eighth Circuit
262 F.3d 843 (2001)
After years of buying defrost control panels from ICM (defendant), Nordyne (plaintiff) requested a new panel to its specifications, and ICM sent a detailed price quotation including quantity, price, a deadline to accept, and specific shipping and payment terms; Nordyne later signed related documentation containing a forum-selection clause after accepting sample panels. When defects surfaced in the panels, Nordyne sued ICM for breach of warranty in federal court, but the district court dismissed for improper venue based on the forum-selection clause, and Nordyne appealed, arguing ICM's original quotation was never a valid offer at all.
Whether a price quotation may be deemed an offer where it includes all the information an offeree needs to accept, such as quantity, price, an acceptance deadline, and shipping and payment terms.