Movado Group, Inc. v. Mozaffarian
Opinion of the Court
Defendants signed a credit agreement in which they expressly acknowledged receipt of, and agreed to be bound by, terms and conditions contained in an extrinsic document, which defendants neither read nor requested a copy to read. After the credit application was approved, defendants saw, for the first time, the terms and conditions, which contained a New York forum selection clause.
Plaintiff proved by a preponderance of the evidence (see Matter of Pickman Brokerage [Bevona], 184 AD2d 226, 226-227
The parties’ dispute is not, as found by the lower court, governed by UCC 2-207 (l)-(2) (b), which provides that, between merchants, where there is an “expression of acceptance or a written confirmation . . . [even if it] states terms additional to or different from those offered or agreed upon . . . [the additional or different terms] become part of the contract unless . . . they materially alter it” (id.). Here, the forum selection clause was not an “additional or different term” added to the contract, nor was it a confirmatory writing; rather, it was one of the terms and conditions incorporated by reference into the contract at its inception (see Guerra v Astoria Generating Co., L.P., 8 AD3d 617, 618 [2004]). Neither of the issues generally decided pursuant to UCC 2-207 are at issue here (see e.g. K I C Chems., Inc. v ADCO Chem. Co., 1996 WL 122420, *4, 1996 US Dist LEXIS 3244, *10 [SD NY 1996] [“a classic ‘battle of the forms’ ”]; Hugo Boss Fashions v Sam’s Eur. Tailoring, 293 AD2d 296, 297 [2002] [a written alteration to an oral agreement]).
We have considered the parties’ remaining arguments and find them unavailing. Concur — Mazzarelli, J.P., Friedman, Catterson, Renwick and Román, JJ. [Prior Case History: 2010 NY Slip Op 33270[U]).]
Case-law data current through December 31, 2025. Source: CourtListener bulk data.