672.201
Formal requirements; statute of frauds.
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672.201 Formal requirements; statute of frauds.—
(1) Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is a record sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by the party’s authorized agent or broker. A record is not insufficient because it omits or incorrectly states a term agreed upon, but the contract is not enforceable under this subsection beyond the quantity of goods shown in the record.
(2) Between merchants if within a reasonable time a record in confirmation of the contract and sufficient against the sender is received and the party receiving it has reason to know its contents, it satisfies the requirements of subsection (1) against the party unless notice in a record of objection to its contents is given within 10 days after it is received.
(3) A contract which does not satisfy the requirements of subsection (1) but which is valid in other respects is enforceable:
(a) If the goods are to be specially manufactured for the buyer and are not suitable for sale to others in the ordinary course of the seller’s business and the seller, before notice of repudiation is received and under circumstances which reasonably indicate that the goods are for the buyer, has made either a substantial beginning of their manufacture or commitments for their procurement; or
(b) If the party against whom enforcement is sought admits in his or her pleading, testimony or otherwise in court that a contract for sale was made, but the contract is not enforceable under this provision beyond the quantity of goods admitted; or
(c) With respect to goods for which payment has been made and accepted or which have been received and accepted (s. 672.606).
History.—s. 1, ch. 65-254; s. 557, ch. 97-102; s. 42, ch. 2025-92.
Note.—s. 2-201, U.C.C.
Notes of Decisions
Cited in 47
cases (10 in the last 5 years), 1972–2025 · leading case: Topp, Inc. v. Uniden American Corp.
Topp, Inc. v. Uniden American Corp. (2007)
“Count I Plaintiff objects to the R & R’s analysis, arguing that (1) Fla. Stat. § 672.201 applies to its claims and thus there is a quantity term sufficient to satisfy the Statute of Frauds; (2) the Statute of Frauds does not apply to fully performed contracts; (3) the R & R…”
White Construction Co. v. Martin Marietta Materials, Inc. (2009)
“The Court agrees that this claim is barred by Florida’s Uniform Commercial Code Statute of Frauds, Fla. Stat. § 672.201 . Pursuant to that section: a contract for the sale of goods for the price of 0 or more is not enforceable by way of action or defense unless there is some…”
Ashland Oil, Inc. v. Pickard (1972)
“requiring a written memorandum signed by the party to be charged for an agreement not to be performed within one year, and § 672.201 Fla. Stat., F.S.A., requiring a written memorandum for the sale of goods for a price of 0.”
Boldstar Technical, LLC v. Home Depot, Inc. (2007)
“Plaintiffs do not dispute that the promise was made orally and never reduced to writing, but contend that the statute of frauds is inapplicable.”
Packaging Corp. International v. Travenol Laboratories, Inc. (1983)
“See Fla. Stat. § 672.201 (3)(b) (1978). 5 In the case sub judice Travenol admitted in its Answer (Paragraph 22) that it made an agreement to purchase thirty million clamps.”
Contractors & Builders Ass'n v. City of Dunedin (1976)
“01 (1973), or which is "for the sale of goods for the price of 0 or more", Fla. Stat. § 672.201 (1973), is unenforceable unless reduced to writing, with certain exceptions not pertinent here.”
OFFICE PAVILION SO. FLA. v. ASAL Products, Inc. (2003)
“Section 672.201(1), Florida Statutes (1997), provides that a contract for the sale of goods in excess of 0 must be in writing to be enforceable.”
Furr v. Corvette Experience, Inc. (In Re Corvette Collection of Boston, Inc.) (2003)
“Fla. Stat. § 672.201 states: Except as otherwise provided in this section a contract for the sale of goods for the price of 0.”
Mettler, Inc. v. Ellen Tracy, Inc. (1994)
“See §§ 672.201-.210, Fla. Stat. (1991). Nevertheless, the second amended complaint does not describe or attach such documents and does not suggest that the standard documents do not exist.”
Future Tech International, Inc. v. Tae Il Media, Ltd. (1996)
“” Fla.Stat. § 672.201(1). In this case, the only signed contract between the parties to this lawsuit is the August 10, 1994 agreement between Plaintiff Future Tech and Defendant Tae II Media.”
Technical Packaging, Inc. v. Hanchett (2008)
“See generally § 672.201, Fla. Stat. (2002); 45 Fla. Jur.”
Centro Nautico v. INTERN. MARINE CO-OP (1998)
“UCC section 672.201 limits enforcement of oral contracts captured by the statute of frauds to only goods for which payment has been made or that have actually been received and accepted.”
— 672.201(1) — 18 cases
OFFICE PAVILION SO. FLA. v. ASAL Products, Inc. (2003)
“Section 672.201(1), Florida Statutes (1997), provides that a contract for the sale of goods in excess of 0 must be in writing to be enforceable.”
Future Tech International, Inc. v. Tae Il Media, Ltd. (1996)
“” Fla.Stat. § 672.201(1). In this case, the only signed contract between the parties to this lawsuit is the August 10, 1994 agreement between Plaintiff Future Tech and Defendant Tae II Media.”
Mettler, Inc. v. Ellen Tracy, Inc. (1994)
“See §§ 672.201-.210, Fla. Stat. (1991). Nevertheless, the second amended complaint does not describe or attach such documents and does not suggest that the standard documents do not exist.”
Packaging Corp. International v. Travenol Laboratories, Inc. (1983)
“See Fla. Stat. § 672.201 (3)(b) (1978). 5 In the case sub judice Travenol admitted in its Answer (Paragraph 22) that it made an agreement to purchase thirty million clamps.”
Topp, Inc. v. Uniden American Corp. (2007)
“Count I Plaintiff objects to the R & R’s analysis, arguing that (1) Fla. Stat. § 672.201 applies to its claims and thus there is a quantity term sufficient to satisfy the Statute of Frauds; (2) the Statute of Frauds does not apply to fully performed contracts; (3) the R & R…”
— 672.201(2) — 3 cases
Topp, Inc. v. Uniden American Corp. (2007)
“Count I Plaintiff objects to the R & R’s analysis, arguing that (1) Fla. Stat. § 672.201 applies to its claims and thus there is a quantity term sufficient to satisfy the Statute of Frauds; (2) the Statute of Frauds does not apply to fully performed contracts; (3) the R & R…”
— 672.201(3) — 1 case
J.R. Sales, Inc. v. Dicks (1988)
— 672.201(3)(b) — 4 cases
OFFICE PAVILION SO. FLA. v. ASAL Products, Inc. (2003)
“Section 672.201(1), Florida Statutes (1997), provides that a contract for the sale of goods in excess of 0 must be in writing to be enforceable.”
Topp, Inc. v. Uniden American Corp. (2007)
“Count I Plaintiff objects to the R & R’s analysis, arguing that (1) Fla. Stat. § 672.201 applies to its claims and thus there is a quantity term sufficient to satisfy the Statute of Frauds; (2) the Statute of Frauds does not apply to fully performed contracts; (3) the R & R…”
Rozema v. Wilson (1982)
— 672.201(3)(c) — 1 case
Centro Nautico v. INTERN. MARINE CO-OP (1998)
“UCC section 672.201 limits enforcement of oral contracts captured by the statute of frauds to only goods for which payment has been made or that have actually been received and accepted.”
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