In Rose v. Spa Realty Associates, 42 N.Y.2d 338, 366 N.E.2d 1279 (1977), the New York Court of Appeals found that the authenticity of amendments is less likely to be an issue where partial performance of the oral modification has been undertaken (Rose v. Spa Realty Associates, 42 N.Y.2d 338, 366 N.E.2d 1279, 397 N.Y.S.2d 922). The Court ruled, however, that the partial performance must be "unequivocally referable to the oral modification." That is, the conduct asserted to overcome the no-oral modification provision must not otherwise be consistent with the original agreement. The doctrine of equitable estoppel, distinct from partial performance, is established by showing that one party to the agreement induced another to act in reliance on the oral modification.