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''Lewis v. Browning'', 130 Mass. 173 (1881). '''Facts''': Plaintiff's offer letter said acceptance should be made by telegraph by a certain date. Plaintiff received acceptance after that date. '''Issue''': Was a contract formed? '''Holding''': No, the terms of Plaintiff's offer was not met. Mailbox rule does not apply. '''Rule''': The mailbox rule does not apply, because the offer clearly outlined that acceptance only occurred upon receipt (by the deadline). [[Category:Cases:Contracts]]