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See also Electronic Signature. A 'subscription' is the same as a 'signing.' Corbin, Contracts, § 521; 4 Williston, Contracts (3 ed.) § 585. A typewritten name is a sufficient subscription. Conlan v. Grace, 36 Minn. 276, 30 N.W. 880; Restatement, Contracts, § 210. 


The statute of frauds does not require the 'memorandum * * * to be in one document. It may be pieced together out of separate writings, connected with one another either expressly or by the internal evidence of subject matter and occasion'. (Marks v. Cowdin, supra, 226 N. Y. 138, 145; see, also, 2 Williston, op. cit., p. 1671; Restatement, Contracts, § 208, subd. [a]. ) Where each of the separate writings has been subscribed by the party to be charged, little if any difficulty is encountered. (See, e.g., Marks v. Cowdin, supra, N. Y. 138, 144-145.) Where, however, some writings have been signed, and others have not there is basic disagreement as to what constitutes a sufficient connection permitting the unsigned papers to be considered as part of the statutory memorandum.


The courts of some jurisdictions insist that there be a reference, of varying degrees of specificity, ...

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