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Sufficiency of a Writing Irving Levin and Harold
Lipton owned the San Diego Clippers Basketball Club, a professional basketball franchise. Levin and Lipton met with Philip Knight to discuss the sale of the Clippers to Knight. After the meeting, they all initialed a three-page handwritten memorandum that Levin had drafted during the meeting. The memorandum outlined the major terms of their discussion, including subject matter, price, and the parties to the agreement. Levin and Lipton forwarded to Knight a letter and proposed sale agreement. Two days later, Knight informed Levin that he had decided not to purchase the Clippers. Levin and Lipton sued Knight for breach of contract. Knight argued in defense that the handwritten memorandum was not enforceable because it did not satisfy the Statute of Frauds. Levin v. Knight, 865 F.2d 1271, Web 1989 U.S. App. Lexis 458 (United States Court of Appeals for the Ninth Circuit) .'1
Was the handwritten memorandum a valid contract? Was it enforceable? Did the Statute of Frauds apply?
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