Muqtadir v. Micro Contacts, Inc.

DAVID A. NELSON, Circuit Judge.

This appeal arises out of a dispute between a manufacturer and a sales representative over post-termination commissions. The key question is whether contract modifications that had been proposed by the sales representative ever became effective, thereby obligating the manufacturer to pay additional commissions. Applying a choice-of-law provision in the parties’ original contract, the district court granted summary judgment to the manufacturer on the ground that the modifications were not effective under New York law.

The sales representative argues on appeal, as…