Digital Signatures <work> in progress Intent and Digital Signatures For example, in Parma Tile Mosaic & Marble Co., Inc. v. Estate of Short, the New York Court of Appeals held that an automatic fax machine heading printed on a document did not satisfy the statute of frauds signature requirement (87 N.Y.2d 524 (N.Y. 1996)). The court held that under the statute of frauds, a valid signature requires an intentional act to authenticate the writing. New York has enacted the Electronic Signatures and Records Act (ESRA), which recognizes that an electronic signature has the same validity and effect as a handwritten signature (N.Y. State Tech. § 304). The ESRA defines an electronic signature the same way the UETA defines it (N.Y. State Tech. § 302(3); see also Uniform Electronic Transactions Act Definition of Electronic Signature). Similar to the UETA, the ESRA applies only to certain transactions. The ESRA generally does not apply to: laws relating to wills, trusts, powers of attorney, or health care proxies; and negotiable instruments and other instruments of the title where possession of the instrument confers title. So even in the United States, we see that not all States (looking at you Louisiana) practice the same standard of what is and is not acceptable. We will ignore the fact that not all digital signatures are "digital signatures". Electronic signatures are different than digital signatures in the sense that digital signatures are considered "legally equivalent" to a handwritten signature. </work>