Since you know so much about this subject why did you bother to ask here?You also can't have a binding verbal contract for the sale of real estate either. Your SOF example doesn't work. If you're going to sell your house, your contract isn't enforceable until it's on paper. It doesn't matter how many verbal contracts or promises you make (unless you want to get some kind of promissory estoppel). Telling people you have a contract because it is in writing does not create a verbal contract. Look, verbal contracts are just that, they are verbal contracts; they are not written. There is probably very little substantive difference in a verbal contract and an oral contract. A court isn't going to look at the difference between a "verbal/oral" whatever you want to call it when determining a remedy unless the case implicates the SOF. In that case, there is no K if you have a verbal OR oral contract. Go pick the bone with your lawyer and quit being such a little female dog on here.