Although the contract would not need to be in writing because of the main benefit exception, it is still dealing with real property and therefore, falls under the Statute of Frauds. The issue is whether Puck can claim a part performance based exception to the Statute of Frauds. The rule is that an oral contract for the sale of real property may be removed from the Statute of Frauds if the part-performance is “unequivocally referable” to the terms of the contract. For example, in Beaver v. Brumlow, the Brumous entered into an oral contract with the Beavers for the sale of their land. The Brumlows spent $85,000 making improvements to the land, creating sewage lines and other permanent constructions. The court ruled that the Brumlows actions,