UCC Section $2-204$ provides three important rules that enable parties to make a contract quickly and informally. Which of the following is NOT one of these rules?

a$.$ A writing sufficient under the Statute of Frauds may be a simple memo, a letter, or informal note, but need not itself be a contract.

b$.$ The parties may make a contract in any manner sufficient to show that they reached an agreement.

c$.$ The UCC will enforce a deal even though it is difficult to say exactly when it was formed.

d$.$ A court may enforce a bargain even though one or more terms were left open.

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