Cases Entores v miles far east corporation (1955) Complaints were a company in London. They sent an offer to purchase 100 tons of copper cathodes to the defendant. The offer was communicated by telex. Miles far east corm sent an acceptance by telex. The issue was where acceptance took place. So in this case, London, not Amsterdam. Lord Denning- held acceptance by telex took place when it was received, and not when it was sent.The postal rule was rejected. The Brimnes (1975) The communication was not an acceptance, but a notice of the withdrawal of a ship from a charter party. It was held to be effective when it was received on the charterers telex machine during office hours, although it was not read until the next morning. Brinkibon ltd v stahag stahl (1983) Brinkibon was based in London. They were buying steel from stahag stahl, based in Austria. The House of Lords approved Entores approach, but did not indicate whether the same rule should apply in all circumstances. Lord Wilberforce stated as follows "No universal rule can cover all such cases: they must be resolved by reference to the intentions of the parties, by sound business practice and in some case by a judgement as to where the risk should lie" Mondial shipping and chartering BR v Astate Shipping ltd (1955) Dealt with a fax giving notice under a contract. Held to be effective when the acceptor could reasonably have expected it to be read. Particularly important in relation to communication such as email and voicemail. The acceptor should be allowed to assume that the communication will be read at a time that could reasonably be expected in the normal course of events. Thomas v BPE Solicitors (2010) An email had been sent at 6pm on a Friday evening before a bank holiday weekend. Defendant solicitors argued that it was not effective when received in the mailbox as it was sent after working with reference to Lord Wilberforce's quote in Brinkibon. It was held that in the context in which that email was sent , it was not to be deemed to be sent after working hours and was therefore effective at 6pm on the Friday if the email was an acceptance. Apple Corps Ltd v Apple computer inc (2004) Greenclose Ltd v national Westminster Bank Plc (2014) Obiter statements. The postal rule does not apply to emails. The phrase giving notice to implied that the person to whom notice was being given must have seen the email- arrival in the inbox would not be sufficient. An offeror can specify and insist on a particular mode of acceptance. In this case, email was not a prescribed mode. Holwell Securities v Hughes (1974). Hughes gave Holwell securities the option to buy his house for 45000 pounds. This option was excercisable by notice in writing within 6 months.The complainants posted a letter agreeing to this option by hughes and this was done 5 days before the 6 month expiry. The Agreement