Andrews, J. | September 18, 2025
In this force-majeure dispute arising out of a contract for the purchase and sale of natural gas based on the North American Energy Standards Board base-contract form, the parties dispute (a) whether the transaction confirmations are part of their contract and (b) which one controls over the other. The Court holds that, although the seller’s transaction confirmation identifies a delivery term on which the buyer’s confirmation is silent, the two confirmations do not materially conflict. Thus, both transaction confirmations combine with the base contract to form a single, integrated agreement, and neither confirmation trumps the other.