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A manufacturer signed an agreement with a parts supplier stating, "Supplier promises to sell circuit boards to Manufacturer at $10 each for one year. Manufacturer promises to buy as many circuit boards as Manufacturer may choose to buy, if any, in Manufacturer's sole discretion." The manufacturer never ordered any boards. The supplier sues, arguing that the manufacturer's promise was consideration.
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The buyer's promise is enforceable because courts ignore consideration in all sale-of-goods contracts. The buyer's promise is consideration because the seller subjectively hoped the buyer would place orders. The buyer's promise is consideration because a written promise can never be illusory. The buyer's promise is illusory if the buyer reserved complete discretion to buy any quantity or no quantity at all based solely on whim.

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