On September 5, 2009, Ralph offered to purchase a farm that Farms Associates had listed for sale in 2008. At one point during the subsequent negotiations, Farms made a counter offer to Ralph, stating that the offer would be valid only until 5 P.M. on October 17th. Farms' attorney sent the offer to Ralph's attorney next day delivery via Federal Express. On October 16th, Ralph sent his acceptance via certified mail to Farms' real estate broker, and Farms received it on October 19th. On October 16th, however, Farms had accepted an offer from another party. Ralph sued Farms, claiming that his acceptance on October 16th was effective on the day that it was sent.

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