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A study of the American decisions relating to the statute of frauds from the standpoint of the Conflict of Laws reveals the fact that there exists the greatest divergence of opinion with respect to contracts falling within the fourth and seventeenth sections of the original English statute of frauds. It is the purpose of this article to consider the problems that have been raised in connection with these cases, and to suggest a solution. Of the contracts falling within the fourth section of the statute of frauds those presented to the courts involving the Conflict of Laws have been generally contracts not to he performed within a year, contracts of guaranty, and contracts relating to land.

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