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E-Signatures: Zulkiewski v. American General Life Insurance Company

E-Commerce Law Reports

A 12 June 2012 unpublished decision of the Michigan Court of Appeals shed light on the necessity for and possible methods of attributing electronic signatures and in the process, found an insurance company's online account service program adequately attributed the electronic signature to the insured. The decision in Zulkiewski v. American General Life Insurance Company (No. 299025, Marquette Circuit Court LC No. 09-047293-CZ, 2012 Mich. App. LEXIS 1086) ended a two-year battle over the $250,000 life insurance of Dr. Ronald Zulkiewski, who committed suicide at age 34.

Originally published in E-Commerce Law Reports, vol. 12, issue 5. Reprinted with permission.