In Thomas J. Kline, Inc. v. Lorillard, Inc., 878 F.2d 791 (4th Cir. 1989), the court interpreted Maryland law as requiring "some writing which indicates ... the quantity to be delivered." Id. at 793.
In Kline, the court found that a memorandum regarding the sale of tobacco products did not adequately specify the quantity of goods being sold, and therefore failed to satisfy the statute of frauds.
"We must consider whether there is any language in the memorandum itself which might satisfactorily indicate 'the quantity to be delivered.' This initial inquiry is plainly required by Maryland's requirement of a written quantity term." Id. at 794.