GPL Treatment, Ltd. v. Louisiana-Pacific Corp.

I disagree with the majority’s conclusion that the documents allegedly sent by plaintiffs to L-P were sufficient to satisfy the UCC Statute of Frauds. The majority’s opinion is at odds with courts from other jurisdictions that have ruled on facts similar to those in this case. Regrettably, it creates an “Oregon exception” to the uniformity that is one of the underlying purposes of the UCC. See ORS 71.1020(2)(c).

According to the majority, the forms sent by plaintiffs to L-P are writings in confirmation of a contract because they are labeled “ORDER CONFIRMATION” and because neither “the…