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UCC 2-207 converts a common law counteroffer into an acceptance even though it states additional or different terms.  Under the common law 'mirror image' rule, 'an invoice from the seller containing terms materially different from those in the buyer's offer would be considered a mere counteroffer,' and not an acceptance of the offer or the formation of a contract. JOM, Inc. v. Adell Plastics, Inc., 193 F.3d 47, 53 (1st Cir. 1999) (per curiam). The Uniform Commercial Code, specifically U.C.C. § 2-207, restricted application of this 'mirror image' rule to certain limited circumstances in which the offer or acceptance was expressly conditioned ...