Mrs. Downing was fitted for dentures by a dentist, Dr. Cook. After she received her dentures, Mrs. Downing began experiencing mouth pain that she attributed to Dr. Cook's manufacture of dentures that did not fit her properly. Mrs. Downing filed suit against Dr. Cook for breach of warranty under Article 2 of the UCC. Dr. Cook defended on the grounds that his denture work was a service and therefore not covered under Article 2 warranties. The trial court found for Mrs. Downing, and Dr. Cook appealed. Is Dr. Cook correct? Are the dentures a contract for services or goods? [Cook v. Downing, 891 P.2d 611 (Oka. App.)] Would silicone breast implants be covered by the UCC Article 2 warranties? Does implantation of silicone gel implants constitute a sale of goods by the surgeon? [In re Breast Implant Product Liability Litigation, 503 S.E.2d 445 (S.C.)]