When a Picture is Not Worth a Thousand Words: Why Emojis Should Not Satisfy the Statute of Frauds’ Writing Requirement


* Benjamin N. Cardozo School of Law, J.D. 2020. The author is grateful to Professor Peter Goodrich for his thoughtful comments throughout this project; to the editors of the Cardozo Law Review for their efforts in developing and editing this Note; and to his family and friends for their support. Most of all, the author would like to thank his dear wife, Feigie, for her encouragement and support, and particularly for her constant review of and advice on this project.