In Forestal Guarani S$.$ A$.$ v$.$ Daros International, Inc., Forestal was a maker of wood finger joints based in Argentina. Daros, a U$.$S$.$ business, orally agreed to sell Forestal's finger joints to third parties in the United States. A dispute arose over the amount Daros owed for the product that Forestal delivered. Argentina, like the United States, had ratified the U$.$N$.$ Convention on Contracts for the International Sale of Goods $($CISG$)$ to govern contracts between merchants for the sale of goods. Unlike the United States, Argentina had made an Article $96$ declaration, which meant the country required that contracts governed by the CISG be in writing. When Forestal sued Daros for the money it claimed Daros owed, Daros argued that the claim was precluded because the contract was not in writing. The appeals court held that