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UCC 2-207 converts a common law counteroffer into an acceptance even though it states additional or different terms. 


[[10463]] 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 ...