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EMPIRE GAS CORP. v. AMERICAN BAKERIES CO.
United States Court of Appeals, Seventh Circuit (1988) | 840 F.2d 1333
TL;DR: Buyer in a requirements contract ordered zero units. The court held the buyer breached due to a bad faith reduction, as no valid business reason was provided, despite an estimated quantity.
Legal Significance: Clarifies UCC § 2-306(1): a buyer's reduction in requirements, even to zero, must be in good faith; the "unreasonably disproportionate" proviso primarily applies to overdemands, not good faith underdemands.