Woodburn Industrial Capital Group, V. Robert Plummer Sr & Robert Plummer Jr., 55135-7

WICG sent Plummer a purchase and sale agreement (PSA) with a 5:00 PM, October 10, 2018 acceptance deadline and a time‑is‑of‑the‑essence clause; the PSA identified the property by street address and tax parcel number.
Plummer did not sign by the deadline. The parties continued communications thereafter about the offer.
On January 8, 2019, WICG allegedly told Plummer the offer remained open; Plummer signed and returned the PSA that same day without changes.
On January 25, 2019 Plummer, through counsel, asserted his January 8 signature was a counteroffer which he revoked; WICG then sued Plummer seeking specific performance.
The superior court granted summary judgment for Plummer and denied WICG’s motion; WICG appealed.
The Court of Appeals concluded genuine issues of material fact exist about whether WICG extended the deadline and whether Plummer’s signature was an effective acceptance; it also held the parcel number satisfied the statute of frauds.

Issue	Plaintiff's Argument (WICG)	Defendant's Argument (Plummer)	Held
Was Plummer’s Jan 8 signature an effective acceptance after the original deadline?	WICG says it extended the deadline (phone call) and Plummer’s signed PSA was acceptance creating an enforceable contract.	Plummer says the original offer expired, his signature was a counteroffer, and he validly revoked it.	Reversed summary judgment for Plummer — existence of an extension and valid acceptance are genuine issues of material fact.
Did the PSA satisfy the statute of frauds (sufficient property description)?	PSA’s tax parcel number (and address) identify the land; statutory authority supports parcel number sufficiency.	Plummer contended the clause “Legal Description to be determined in Escrow” negated the parcel number’s sufficiency.	Parcel number is sufficient; PSA satisfies the statute of frauds.
Is Plummer entitled to attorney’s fees under the contract?	— (WICG argued contract existed entitling prevailing party to fees)	Plummer sought fees as prevailing party even if no enforceable contract existed.	No fees to Plummer on appeal because summary judgment was improperly granted and he is not the prevailing party.

Geonerco, Inc. v. Grand Ridge Props. IV LLC, 146 Wn. App. 459, 191 P.3d 76 (Wash. Ct. App. 2008) (contracts conveying real property require sufficient land description)
Hearst Communications, Inc. v. Seattle Times Co., 154 Wn.2d 493, 115 P.3d 262 (Wash. 2005) (adopts objective manifestation theory for contract formation)
Key Design, Inc. v. Moser, 138 Wn.2d 875, 983 P.2d 653 (Wash. 1999) (statute of frauds requires description identifying property without oral testimony)
Strauss v. Premera Blue Cross, 194 Wn.2d 296, 449 P.3d 640 (Wash. 2019) (standard of review for summary judgment)
Roats v. Blakely Island Maint. Comm’n, Inc., 169 Wn. App. 263, 279 P.3d 943 (Wash. Ct. App. 2012) (context rule permits extrinsic evidence to interpret contracts)