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  Examination of UCC 1-203 and UCC 2-201 leads us to the conclusion that promissory estoppel should be allowed to defeat reliance upon the UCC Statute of Frauds. The central issue is whether promissory estoppel is specifically displaced. Some states hold that if the legislature did not want estoppel to apply to application of the Statute of Frauds, it would have stated that intent expressly. Courts in other states are split on this issue. Among those cases that have held that promissory estoppel is not an exception to the UCC Statute of Frauds are: Ivey's Plumbing & Elec. Co. v. Petrochem Maintenance, ...