Liork, LLC v. BH 150 Second Avenue, LLC, Case No. 3D16-1881 (Fla. 3d DCA 2018).
Subscription agreements are not subject to lack of mutuality attacks because they are different from bilateral contracts where one party promises to perform a specific action directly in exchange for the other party performing another specific action, like a sale and purchase agreement.

Subscription agreements are not subject to lack of mutuality attacks because they are different from bilateral contracts where one party promises to perform a specific action directly in exchange for the other party performing another specific action, like a sale and purchase agreement. The court found that a subscription agreement signed by an investor was enforceable because the investor agreed to pay a certain amount of money, and in exchange, was to receive an interest in the business venture, and, as such, the trial court correctly refused to void the subscription agreement on the ground that it lacked mutuality of obligations.