could be paid to either payee individually); Manufacturers’ News, Inc. v. Indus. Guides, Inc., 1997 WL 567802, at *3, 1997 U.S. Dist. LEXIS 13608, at *8-9 (N.D.Ill. Sept. 2, 1997) (dismissing conversion claims because the UCC required the ambiguous check to be construed as payable to the persons alternatively). 33 . Harder v. First Capital Bank, 332 Ill.App.3d 740, 266 Ill.Dec. 770, 775 N.E.2d 610, 614 (2002). 34 . See Pelican Nat’l Bank v. Provident Bank of Md., 381 Md. 327, 849 A.2d 475 (2004) (providing recent and extensive analysis of the stacked payee format; examining the 1990 version of the UCC and Illinois cases specifically; determining that stacked payees are paid in the alternative); Allied Capital Partners, L.P. v. Bank One, Texas, N.A., 68 S.W.3d 51, 54-55 (Tex.App.2001) (<HOLDING>). Because the UCC is a uniform law, the court
holding that the repeated sending of a writing which contains certain standard terms without any action with respect to the issues addressed by those terms cannot constitute a course of dealing which would incorporate a term of the writing otherwise excluded under  2207 because the repeated exchange of forms by the parties only tells buyer that seller desires certain terms given sellers failure to obtain buyers express assent to these terms before it will ship the program buyer can reasonably believe that while seller desires certain terms it has agreed to do business on other terms those terms expressly agreed upon by the parties holding that courts are without power to construe an unambiguous statute in a way which would extend modify or limit its express terms holding that payees stacked without punctuation marks or connecting terms are paid in the alternative holding because legislature knew how to include terms within statutory definition and did not do so statutory definition did not include terms in light of the terms contemporaneous inclusion of the same terms in a separate provision holding the state of kansas not necessary based on the terms of the settlement agreement at issue before going on to find in the alternative that it was not indispensable