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The day first became associated with romantic love within the circle of Geoffrey Chaucer in the 14th century, when the tradition of courtly love flourished.

In 18th-century England, it evolved into an occasion in which lovers expressed their love for each other by presenting flowers, offering confectionery, and sending greeting cards (known as "valentines").

Section 1694 et seq., referred to here as the dating service statutes, prescribe certain standards and language that must be included in dating service contracts. (Ibid.) We conclude that under California law, these “consulting agreements” are part of a small class of contracts regulated by specific statutes that expressly render nonconforming contracts void and unenforceable. FACTUAL AND PROCEDURAL BACKGROUNDRespondents individually entered into three-year “consulting agreements” (the agreements) with Valenti for matchmaking services. Where the statute prescribes the only mode by which the power to contract is to be exercised, that mode is the measure of the power.

Valenti brought a motion to compel arbitration, arguing that the arbitration clause within the matchmaking consulting agreement was severable and enforceable, regardless of any potential defenses to the underlying contract liability. Proc., §§ 1281, 1281.2.) The superior court denied the motion, concluding the arbitration clause was unenforceable because it was contained within an agreement that lacked essential language required by the statutory scheme, and the agreement was entered into under misleading circumstances, also a violation of statute. (a), (b).)On appeal, Valenti argues the superior court erred when it determined the agreements were illegal under California law, and that in any case, the arbitration clauses within them should have remained enforceable under state or federal law. Rptr.2d 875, 926 P.2d 1061 (Rosenthal ), the particular causes of action in the underlying complaints, for purposes of determining arbitrability of fraud allegations related to contract (fraud in the inception or execution, as opposed to fraud in the inducement). Because the agreements sued upon violated express requirements of the dating service statutes that clearly apply here, they are void and unenforceable, and their arbitration provisions are likewise not enforceable. The agreements stated that the company was not intended to be a dating service, but rather, “[i]t is a matchmaking service in the traditional sense.” In exchange for respondents' retainer fees, Valenti promised to help respondents establish “personal relationships” by analyzing their personal data and matching them with eligible persons of the opposite sex. Rptr.2d 147.) Generally, procedural state rules are not preempted by the FAA if the parties have agreed “to arbitrate in accordance with California law.” (Volt Information Sciences, Inc. A contract made otherwise than as so prescribed is not binding or obligatory as a contract, and the doctrine that there is an implied liability arising from the receipt of benefits has no application․ Under such circumstances, the express contract attempted to be made is not invalid merely by reason of some irregularity or some invalidity in the exercise of a general power to contract, but is void because the statute prescribes the only method in which a valid contract can be made.

In Europe, Saint Valentine's Keys are given to lovers "as a romantic symbol and an invitation to unlock the giver’s heart", as well as to children, in order to ward off epilepsy (called Saint Valentine's Malady).

Valentine's Day symbols that are used today include the heart-shaped outline, doves, and the figure of the winged Cupid.

At the epicenter of California’s withering drought is the oasis of Rancho Santa Fe, lush with tropical plants, lemon groves and acre after acre of grass.

The upscale enclave earned the dubious distinction of having the state’s highest per-capita residential water use in September, when regulators began collecting that type of monthly calculation for water districts statewide.

Phone chat lines are still around, with two large competitors dominating. Several unscrupulous brick & mortar chains (Great Expectations, Together/The Right One) went out of business.Since the 19th century, handwritten valentines have given way to mass-produced greeting cards.Many parts of the Eastern Orthodox Church also celebrate Saint Valentine's Day, albeit on July 6 and July 30, the former date in honor of the Roman presbyter Saint Valentine, and the latter date in honor of Hieromartyr Valentine, the Bishop of Interamna (modern Terni).Resolving these arguments requires us to analyze, under the standards of Rosenthal v. Each agreement contained a clause, which respondents individually initialed, that required the parties to submit disputes to arbitration. The adoption of the prescribed mode is a jurisdictional prerequisite to the exercise of the power to contract at all, and that power can be exercised in no other manner.” (Ibid., fns.omitted.)That parallel authority suggests that if a statute prescribes the only method in which a valid contract can be made, a contract that fails to follow that method is void.The arbitration clauses were followed by provisions stating that California provided the governing law and the forum for resolution of any disputes arising under or relating to the agreement. Omitting required provisions, as here, does not follow the requirements of statute.

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