Units; Statute of Frauds – Texas. On June 12, in Cabot Oil & Gas Corp. v. Newfield Exploration Mid-Continent Inc. (Case No. 07-16-00125-CV), the Texas Court of Appeals for the Seventh District held that a well operator that retained an interest in a 160 acre proration unit surrounding a specific well did not satisfy the statute of frauds because none of the operative agreements described the unit with sufficient specificity. Read more: https://scholar.google.com/scholar_case?case=3436150539341863332&hl=en&as_sdt=6&as_vis=1&oi=scholarr