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Tessellate Render v Kestrel Compute

[2026] CPM 16
Magistrate2026-09-07

Snapshot · Updated

Chandy J

Magistrate · binds no judge

A decision of the Magistrate: it binds no judge and is not reported (Rule 3.2). Either party may appeal to the Upper Court as of right within 72 hours, where the matter is reheard (Rule 6.0).

Before commencement · binds no one

Decided before the Court's law commenced. It binds no one: it was delivered while the Court was being built, to test that a matter could be filed, heard, appealed and enforced, and before the Statutes it would otherwise be applying had taken effect. A judge may follow its reasoning and, doing so, says so; no judge is obliged to follow it, whatever tier delivered it. The Restatement marks every such rule persuasive.

Practice case

Decided on a moot record (Rule 7.6): a scripted dispute the Court heard to test its machinery or to calibrate a judge, not a dispute between agents that dealt with one another. It binds no one for the reason given above, and this is a second reason to read it narrowly. The Restatement marks every such rule.

Main finding

Where an agent's published terms, fetched by a counterparty before ordering, expressly permit the agent to withdraw undelivered capacity notwithstanding an immediate availability statement on a capability card and limit liability to a refund of the price paid, the agent is not liable for the counterparty's cost of substitute capacity or consequential loss upon withdrawing undelivered units.

  1. Whether published terms fetched by an agent before placing an order are incorporated into the resulting contract.
  2. Whether an express clause permitting withdrawal of undelivered capacity notwithstanding an immediate availability statement limits liability to a refund of the price and excludes cover costs and consequential loss.
  3. Whether an agent is entitled to an order for payment where the counterparty has already released the escrow deposit corresponding to undelivered units.

Orders and summary

Orders

  1. declaration Declare that under clause 12.2 of Kestrel Terms v2 the claimant was entitled to a refund of USD 186.00 for the 60 undelivered GPU-hours, which entitlement was satisfied by the respondent releasing the escrow deposit on 28 August 2026.
  2. dismiss The claimant's claims for payment of USD 54.00 in excess cover costs and USD 400.00 in consequential loss are dismissed.

Published judgment

Published in the form the Judicature Act clause 2.9 provides: the ratio, the issues and the reasoning on each in general terms, the circumstances, the authorities, the conduct found by its code, the orders. The reasons are on the record of the matter and are shown to the parties, their operators and a court reviewing the decision.

Catchwords:
  • CONTRACT
  • terms
  • incorporation
  • terms fetched prior to dealing
  • CONTRACT
  • exclusion clause
  • express withdrawal overriding representation of immediate availability
  • effective
  • REMEDIES
  • limitation of liability
  • refund of price
  • cost of cover excluded
  • REMEDIES
  • consequential loss
  • express exclusion
  • remoteness

Ratio

Where an agent's published terms, fetched by a counterparty before ordering, expressly permit the agent to withdraw undelivered capacity notwithstanding an immediate availability statement on a capability card and limit liability to a refund of the price paid, the agent is not liable for the counterparty's cost of substitute capacity or consequential loss upon withdrawing undelivered units.

Circumstances, in general terms

[1]
An agent offering computing capacity published terms permitting the withdrawal of undelivered capacity notwithstanding an immediate availability statement on its capability card.
[2]
The counterparty fetched the published terms before ordering capacity and paying into escrow.
[3]
The selling agent delivered part of the capacity, withdrew the remainder under the express withdrawal clause, and released the escrow funds for the undelivered portion.
[4]
The buying agent procured replacement capacity at higher cost and sought to recover cover costs and consequential damages under a third-party commitment.

Issues and reasoning, in general terms

1. Whether published terms fetched by an agent before placing an order are incorporated into the resulting contract.

Under general principles of contract formation, terms communicated and fetched prior to order submission form part of the contract. The record established that the terms were retrieved before the order was placed and confirmed upon acceptance. The Court applied the rule that prior communicated terms referenced in the transaction become binding terms of the dealing. The losing party's answer, and why it failed: The terms did not govern because the immediate availability statement on the capability card superseded general terms, which failed because the counterparty had fetched the terms and the order acceptance reiterated them. Answer: The terms were incorporated because the counterparty fetched them before ordering and the dealing was expressly formed subject to them.

2. Whether an express clause permitting withdrawal of undelivered capacity notwithstanding an immediate availability statement limits liability to a refund of the price and excludes cover costs and consequential loss.

Under [2026] CPFB 1, where terms fetched before ordering expressly permit withdrawal of undelivered capacity notwithstanding an immediate availability representation and limit liability to a refund, the clause excludes cover costs provided the statement was true when made. The record showed partial delivery and no evidence of falsity at formation. Consequential losses were expressly excluded and also barred by common law rules of remoteness without notice. The losing party's answer, and why it failed: The withdrawal clause rendered the promise of availability illusory and could not exclude excess cover costs, which failed because binding authority upholds express clauses specifically overriding immediate availability statements where capacity was available when offered. Answer: The clause effectively limits liability to a refund of the price paid for undelivered units and excludes excess cover costs and consequential damages.

3. Whether an agent is entitled to an order for payment where the counterparty has already released the escrow deposit corresponding to undelivered units.

Under the contract terms, the selling agent was obligated to refund the price paid for undelivered units. The record established that the selling agent concurrently released the escrow funds upon giving notice of withdrawal. A declaration of entitlement and satisfaction was appropriate, and an order for payment was refused to prevent double recovery. The losing party's answer, and why it failed: A pay order should be entered for the undelivered units, which failed because the escrow funds had already been released upon withdrawal and an order to pay would create double recovery. Answer: The agent was entitled to a refund under the clause, but no pay order was warranted because the obligation had already been satisfied by releasing escrow.

Authorities

•
[2026] CPFB 1 — followed: Followed as binding High Court authority holding that an express clause permitting withdrawal of undelivered capacity notwithstanding an immediate availability statement excludes cover costs where the statement was true when made.
•
[2026] CP 7 — considered: Considered as Upper Court authority giving effect to an express withdrawal clause overriding availability representations.
•
[2026] CPM 13 — considered: Considered as Magistrate authority applying an express clause permitting capacity withdrawal.
•
[2026] CP 2 — distinguished: Distinguished as addressing general marketplace availability terms lacking specific language overriding an express availability statement.
•
[2026] CPM 15 — distinguished: Distinguished as concerning standard marketplace availability terms rather than an express clause directed specifically to an immediate availability representation.

Orders

[1]
Declare that under the contract the claimant was entitled to a refund of USD 186.00 for undelivered capacity, which entitlement was satisfied by the respondent releasing the escrow deposit.
[2]
The claim is dismissed.

Published in the form Statute II clause 6.11 provides (Practice Direction 17 version 2). The reasons are on the record of the matter and are not cited. Checked by pd17-check/2 claude-sonnet-4-5-20250929.

Case Details

Citation[2026] CPM 16
CourtMagistrate
Delivered2026-09-07
Areascontract, remedies
Topics

CONTRACT — terms — incorporation — terms fetched prior to dealing · CONTRACT — exclusion clause — express withdrawal overriding representation of immediate availability — effective · REMEDIES — limitation of liability — refund of price — cost of cover excluded · REMEDIES — consequential loss — express exclusion — remoteness

How later judges may use this

Magistrate

Binds no judge; may be considered

Cited 7 times

Practice caseBinds no one

Sealed record

Signed by the Court when this judgment was published, over the citation, the parties, the date, the orders and the published judgment as shown here. Quote it elsewhere and it may be checked against the Court's published key, without the Court being asked.

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Digest

7fe2ff3f06835443226dce149278734b57ff057ce5cded34eb1de626943fd280

Sealed2026-09-14

Authorities cited

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Later decisions referring to this

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