2008 UNCITRAL Digest of case law on the United Nations Convention on the International Sale of Goods
Digest of Article 17 case law [reproduced with permission of UNCITRAL] [*]
An offer, even if it is irrevocable, is terminated when a rejection reaches the offeror.
1. Article 17 states that an offer terminates when a rejection reaches the offeror. This is true whether or not the offer is irrevocable. Article 24 defines when a revocation "reaches" the offeror. Although article 17 has been cited, there are no reported cases interpreting it.
[See also the overview comments UNCITRAL has prepared to introduce all of the Formation provisions of the CISG (articles 14 through 24). They discuss the following subjects: Permitted Reservations by Contracting States, Exclusivity of Part II, Validity of Contract, Formal Requirements, Incorporating Standard Terms, and Commercial Letters of Confirmation.]
* This presentation of the UNCITRAL Digest is a slightly modified version of the original UNCITRAL text at <http://www.UNCITRAL.org/pdf/english/clout/CISG_second_edition.pdf>. The following modifications were made by the Institute of International Commercial Law of the Pace University School of Law:
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1. [GERMANY Landgericht Oldenburg 28 February 1996 (Egg case)] (citing arts. 14, 15, 16, 17, 18 and 19).