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There is a considerable split of authority regarding whether a document sent after the delivery of goods qualifies  as a 'written confirmation' capable of modifying the parties' agreement under UCC § 2-207. Compare Cosden Oil & Chem. Co. v. Karl O. Helm Aktiengesellschaft, 736 F.2d 1064, 1075-76 (5th Cir. 1984) (applying Texas's UCC provisions and finding that an invoice sent after the shipment of goods did not modify the contract pursuant to § 2-207), and Wheaton Glass Co. v. Pharmex, Inc., 548 F. Supp. 1242, 1244 (D.N.J. 1982) (same, applying New Jersey's UCC provisions), and 1 White & Summers, Uniform Commercial ...