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Hanil Bank v. Perseroan Terbatas Bank Negara Indonesia
United States District Court for the Southern District of New York
No. 96 Civ. 3201, 41 U.C.C. Rep. Serv. 2d 618 (2000)
Kodeco Electronics (Kodeco) had Bank Negara Indonesia (BNI) (defendant) issue a letter of credit in favor of Sung Jun Electronics (Sung Jun). BNI issued a letter in favor of Sung Jin Electronics (Sung Jin) by mistake. Sung Jun sold the letter to Hanil Bank (Hanil) (plaintiff). When Hanil submitted the required documents under the letter to BNI for payment, BNI denied payment. BNI did so because the submitted documents did not strictly comply with the letter, as the letter was issued to Sung Jin and not Sung Jun. Hanil filed suit in the United States District Court for the Southern District of New York against BNI for payment, arguing that a misspelling is not an error that absolves an issuer of a letter of credit from an obligation to make payment when presented with the required documents. Hanil and BNI filed cross-motions for summary judgment.
Rule of Law
Holding and Reasoning (Keenan, J.)
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