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module two transactional elements of sales contracts statute of frauds Salvador Dali painter who in the 1950s was commissioned to paint the Statue of Liberty for a television show when dolly did not perform as allegedly agreed the other party sued dolly argued that the agreement to paint constituted a sale of goods under the UCC and was therefore subject to the codes requirement that there be a written record for sales of goods the court ruled that the arrangement to procure the painting was not a sale of a good so dolly lost the codes requirement that there be a writing is the UCCS version of the statute of frauds to address what was then perceived to be a widespread problem with contractual fraud the english parliament passed the original statute of frauds in 1677 the statute required certain types of contracts including sales of goods to be in writing in order to be enforceable england repealed its legislation in 1954 as it pertained to the sale of goods but the UCC continues to enf