In the context of aircraft transactions, parties should be especially mindful of deviations from delivery dates and delivery conditions to ensure that such deviations do not evidence an "indisputable mutual departure" from the written agreement.Notes1Aircraft Services Resales LLC v. Oceanic Capital Co. Ltd., No. 13 Civ. 3738, __ Fed. Appx. __, 2014 WL 5032409 (2d Cir. Oct. 9, 2014). As a "summary decision," the decision does not have precedential effect but may be cited.2See, e.g.,Austrian Airlines Oesterreichische v. UT Finance Corp., 567 F. Supp. 2d 579, 592 (S.D.N.Y. 2008), aff’d, 336 Fed. Appx. 39, 2009 WL 1940715 (2d Cir. July 2, 2009) (the aircraft purchase agreement would have required a writing to modify the delivery date); Dallas Aerospace, Inc. v. CIS Air Corp., 352 F.3d 775 (2d Cir. 2003) (suggesting that N.Y. U.C.C. §2-209 would have applied if the agreement excluded modifications).3 Under N.Y. U.C.C. 2-201, a contract for the sale of goods for the price of $500 or more is not enforceable in the absence of a sufficient writing signed by the party against whom enforcement is sought.4See Austrian Airlines, 567 F. Supp. 2d at 593.5Compare Austrian Airlines, 567 F. Supp. 2d at 593 (communications by an aircraft purchaser concerning possible extension of the delivery date did not evidence an "indisputable mutual departure" from the aircraft purchase agreement).