10. Sammy entered into an oral contract with Macaulay for the sale of goods amounting to $900. Sammy paid the amount, but Macaulay refused to deliver the goods. Sammy suffered serious losses because of Macaulay's breach of contract. Sammy sued Macaulay. Macaulay alleged the statute of frauds as a defense. Under which principle is Sammy protected as an exception to the statute of frauds? A. Tortious liability B. Vicarious liability C. Part performance D. Promissory estoppel