UCC Warranties: Express and Implied Warranties in the Sale of Goods
Last updated on September 9, 2026
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This analysis is part of our comprehensive reference guide on Business Law.
Table of Contents
UCC Warranties: Express and Implied Warranties in the Sale of Goods
Introduction
When a person buys a product, the law does not necessarily leave the buyer entirely dependent on whatever the seller happens to promise.
Under Article 2 of the Uniform Commercial Code (UCC), sales of goods can carry legally enforceable warranties concerning the quality, characteristics, performance, and suitability of those goods.
Some warranties are created expressly by the seller’s words or conduct.
Others arise automatically by operation of law.
This distinction is fundamental.
A seller might say:
“This refrigerator uses 30% less electricity than comparable models.”
That statement may create an express warranty if it becomes part of the basis of the bargain.
Alternatively, the seller may say nothing about the refrigerator’s ordinary operation. If the seller is a merchant dealing in refrigerators, the law may nevertheless impose an implied warranty of merchantability.
The UCC therefore recognizes that contractual obligations concerning goods can arise from more than the formal words “I warrant.”
Cornell Law School’s Legal Information Institute defines a warranty under U.S. law as a legally binding promise, assurance, or statement concerning matters such as the condition, quality, quantity, or nature of goods. Under Article 2, warranties form an important part of the legal relationship between buyers and sellers.
The major categories include:
- express warranties;
- implied warranty of merchantability;
- implied warranty of fitness for a particular purpose;
- warranties arising from course of dealing or usage of trade;
- and, in appropriate circumstances, warranties concerning title and related matters.
Understanding UCC warranties requires more than memorizing their names.
The important questions are:
How is the warranty created?
What exactly does it promise?
Can it be disclaimed or limited?
What happens when the goods fail to conform to the warranty?
1. What Is a Warranty Under the UCC?
A warranty is a legally enforceable assurance concerning the goods or the seller’s obligations regarding those goods.
A warranty can concern:
- quality;
- condition;
- performance;
- characteristics;
- description;
- suitability;
- or other legally relevant aspects of the transaction.
A warranty is not necessarily a separate contract.
It can be part of the sales contract itself.
For example:
“These generators are capable of producing 10,000 watts continuously.”
If that statement becomes part of the bargain, the seller may have made an express warranty.
If the generators cannot perform as represented, the buyer may have a claim for breach of warranty.
2. The Three Major UCC Warranty Categories
For sales of goods, three categories are particularly important:
Express warranties
Created by affirmations, promises, descriptions, samples, or models.
Implied warranty of merchantability
Generally arises when a merchant sells goods of the relevant kind.
Implied warranty of fitness for a particular purpose
May arise when the seller knows the buyer’s particular purpose and knows the buyer is relying on the seller’s skill or judgment.
These warranties serve different functions.
| Warranty | Basic Question |
|---|---|
| Express warranty | What did the seller represent about the goods? |
| Merchantability | Are the goods fit for their ordinary purposes? |
| Fitness for particular purpose | Are the goods suitable for the buyer’s known special purpose? |
The distinction between ordinary fitness and particular fitness is especially important.
3. Express Warranties Under UCC § 2-313
An express warranty can arise from an affirmation of fact or promise made by the seller concerning the goods.
For example:
“This laptop contains 32 GB of RAM.”
If the statement becomes part of the basis of the bargain, it may constitute an express warranty.
The seller does not necessarily need to use the word “warranty.”
A seller can create an express warranty simply by making a factual representation about the goods.
This is an important feature of UCC sales law.
A seller cannot necessarily avoid warranty obligations merely by avoiding formal warranty terminology.
4. Descriptions of Goods Can Create Express Warranties
An express warranty can also arise from a description of the goods.
Suppose a seller advertises:
“All jackets are made from 100% genuine leather.”
A buyer purchases a jacket based on that description.
If the jacket is made entirely from synthetic material, the description may have created an express warranty that the goods would conform to that representation.
The key issue is whether the description became part of the basis of the bargain.
The buyer does not necessarily need a separate sentence stating:
“Seller expressly warrants that this jacket is leather.”
The factual description itself can carry legal significance.
5. Samples and Models
Express warranties can also arise from a sample or model.
Imagine a manufacturer shows a buyer a sample of a particular fabric.
The buyer then orders 10,000 yards based on that sample.
The sample may become part of the basis of the bargain.
If the delivered fabric differs materially from the sample, the buyer may have a breach-of-warranty claim.
The principle is simple:
What the seller uses to describe or demonstrate the goods can become part of the contractual promise.
6. Puffery vs. Express Warranty
Not every statement made by a seller creates an express warranty.
Commercial advertising often contains exaggerated statements such as:
“The world’s greatest coffee.”
“The finest shoes money can buy.”
These statements may be understood as puffery rather than specific factual commitments.
Compare that with:
“These shoes are waterproof for up to eight hours.”
The second statement is specific and objectively testable.
The more precise and factual the representation, the more likely it is to be treated as an express warranty.
The distinction is therefore between:
general promotional opinion
and
specific factual representation.
7. Reliance and the Basis of the Bargain
The concept of the basis of the bargain is central to express warranties.
Courts examine whether the seller’s affirmation, description, sample, or model became part of the transaction between the parties.
The question can be framed as:
Was this representation sufficiently connected to the transaction to become part of what the buyer purchased?
Cornell’s discussion of the UCC basis-of-the-bargain test explains that courts use this concept when determining whether a seller’s representation became part of the bargain under UCC § 2-313.
Different jurisdictions may approach reliance somewhat differently, so the precise doctrinal test should be checked under applicable state law.
8. Implied Warranty of Merchantability
The implied warranty of merchantability addresses the ordinary quality and usefulness of goods.
Under UCC § 2-314, the warranty generally arises when:
- a sale of goods occurs;
- the seller is a merchant with respect to goods of that kind; and
- the warranty has not been effectively excluded or modified.
Cornell’s Wex explanation of the implied warranty of merchantability explains that the warranty generally means goods must be fit for the ordinary purposes for which such goods are used.
The underlying idea is straightforward:
A commercial seller should generally deliver goods that function as goods of that type ordinarily function.
9. What Does “Merchantable” Mean?
Merchantability does not mean perfection.
A product can be merchantable even though it has minor imperfections.
The relevant question is whether the goods satisfy ordinary commercial expectations.
Under UCC § 2-314, merchantable goods must generally:
- pass without objection in the trade under the contract description;
- satisfy applicable quality standards;
- be fit for their ordinary purposes;
- be adequately contained, packaged, and labeled where appropriate;
- and conform to applicable promises or affirmations appearing on containers or labels.
Thus, a product does not have to be the best available.
It must generally be fit for its ordinary purpose.
10. Example of Merchantability
Suppose a retailer sells a new toaster.
The buyer does not need to negotiate a special promise that the toaster will toast bread.
That is its ordinary purpose.
If the toaster cannot toast bread at all, it may violate the implied warranty of merchantability.
The warranty therefore supplies a baseline expectation even if the seller made no express promise concerning the product.
11. Who Owes the Implied Warranty of Merchantability?
The implied warranty of merchantability generally applies when the seller is a merchant with respect to goods of that kind.
This connects directly to the preceding article on merchant status.
A person selling a used refrigerator from their home does not necessarily occupy the same legal position as a retailer whose business is selling refrigerators.
The law distinguishes between an occasional private seller and a professional commercial seller.
This reflects the commercial justification behind the warranty.
12. Implied Warranty of Fitness for a Particular Purpose
The implied warranty of fitness for a particular purpose is different.
It concerns the buyer’s specific purpose, rather than the ordinary purpose of the goods.
Under UCC § 2-315, the warranty can arise when:
- the seller has reason to know the buyer’s particular purpose;
- the seller has reason to know that the buyer is relying on the seller’s skill or judgment; and
- the buyer in fact relies on that skill or judgment in selecting the goods.
The seller does not necessarily need to be a merchant.
This is an important distinction from merchantability.
13. Ordinary Purpose vs. Particular Purpose
Consider a buyer purchasing a standard ladder.
Merchantability
The buyer expects the ladder to function as an ordinary ladder.
That is its ordinary purpose.
Fitness for a particular purpose
Suppose the buyer tells the seller:
“I need a ladder capable of safely reaching a 40-foot roof.”
The seller recommends a particular ladder.
The buyer relies on that recommendation.
If the ladder is incapable of safely reaching the stated height, the facts may support a warranty-of-fitness claim.
The distinction can be summarized:
Merchantability concerns ordinary use.
Fitness concerns a particular use communicated to the seller.
14. The Seller’s Knowledge Matters
Fitness for a particular purpose depends heavily on what the seller knew.
Suppose Buyer purchases a standard camera without telling the seller anything about its intended use.
Later, Buyer decides to use it for underwater photography.
The seller may not have known about that special purpose.
The implied warranty of fitness may therefore not arise.
Now change the facts.
Buyer tells the seller:
“I need a camera specifically for underwater photography at significant depths.”
The seller recommends a particular model.
Buyer relies on the seller’s recommendation.
The analysis changes substantially.
The seller’s knowledge and the buyer’s reliance are central.
15. Merchantability and Fitness Can Exist Together
These warranties are not necessarily mutually exclusive.
A product can be:
- merchantable for ordinary purposes; but
- unsuitable for a particular purpose.
For example, a standard camera may work perfectly for ordinary photography but be unsuitable for deep-water photography.
Conversely, a product may be specifically suitable for a buyer’s unusual purpose but still fail ordinary quality requirements.
The two warranties therefore address different risks.
16. Warranties Created by Course of Dealing and Usage of Trade
The UCC also recognizes that warranties can arise from the parties’ commercial relationship and industry practices.
The parties may have a history of dealing in a particular way.
Alternatively, a trade may have established practices that help determine what the parties reasonably expected.
For example, if a particular industry consistently uses a recognized technical specification when referring to a product, that practice may influence the interpretation of a sales contract.
The written contract is therefore not always the entire universe of relevant commercial meaning.
17. Warranties and Contract Interpretation
Warranties often become relevant when the parties disagree about what the seller actually promised.
Suppose a contract describes machinery as:
“Industrial-grade equipment suitable for continuous commercial operation.”
The buyer later discovers that the machinery overheats after two hours.
The court may need to determine whether the language created an express warranty.
The question is not merely:
“Did the contract contain the word warranty?”
Instead:
What did the seller represent about the goods, and did that representation become part of the bargain?
18. Express Warranties Do Not Always Require Formal Language
The UCC does not generally require magical words.
A seller does not have to say:
“I hereby create an express warranty.”
A factual promise may be enough.
For example:
“This engine will operate continuously for 5,000 hours.”
That statement may create a warranty even though the seller never uses the word “warranty.”
This principle protects buyers from technical formalism.
19. What Happens When Express and Implied Warranties Conflict?
Sometimes a contract contains an express warranty but also includes language attempting to disclaim implied warranties.
For example:
“The machine will operate at 500 units per hour.”
The same contract might say:
“Seller disclaims all warranties.”
The two provisions may conflict.
The UCC attempts, where reasonably possible, to interpret contractual provisions consistently.
But a disclaimer cannot necessarily erase an express promise merely by using broad language.
This is particularly important when the contract contains specific representations about the goods.
20. Disclaiming the Implied Warranty of Merchantability
The UCC permits certain disclaimers of implied warranties.
But specific requirements apply.
To exclude or modify the implied warranty of merchantability, the disclaimer generally must mention merchantability.
If the disclaimer is written, it generally must also be conspicuous.
For example:
“SELLER DISCLAIMS THE IMPLIED WARRANTY OF MERCHANTABILITY.”
This language directly addresses the relevant warranty.
A vague statement buried in fine print may not satisfy the statutory requirements.
21. Disclaiming the Warranty of Fitness
The implied warranty of fitness for a particular purpose has its own requirements.
A written disclaimer generally must be conspicuous.
The UCC therefore does not treat every general disclaimer as automatically sufficient.
The purpose is to ensure that a buyer receives meaningful notice when statutory protections are being limited.
22. “As Is” and “With All Faults”
The UCC also recognizes certain language that can exclude implied warranties.
Examples include:
“AS IS”
and
“WITH ALL FAULTS.”
Such language can be effective in appropriate circumstances because it communicates that the seller is not providing ordinary implied-warranty protection.
But the precise circumstances and effectiveness of a disclaimer can depend on:
- the language used;
- the transaction;
- applicable statutory requirements;
- the surrounding circumstances;
- and state law.
A disclaimer should therefore not be treated as automatically effective merely because the words “as is” appear somewhere in a document.
23. Examination of the Goods
The buyer’s opportunity to examine goods can also matter.
Under UCC § 2-316, if the buyer examines the goods, sample, or model as fully as desired, or refuses to examine them, certain implied warranties may not apply to defects that the examination should reasonably have revealed.
The principle is one of risk allocation.
A buyer should not necessarily be permitted to complain about an obvious defect that was fully available for inspection before purchase.
But this principle does not mean that examination eliminates every possible warranty claim.
The particular defect and warranty must be analyzed.
24. Warranty Disclaimers and Commercial Bargaining
Warranty disclaimers are common in commercial contracts because businesses frequently allocate risk through contract language.
A seller may seek to limit warranties to:
- repair;
- replacement;
- refund;
- or another specified remedy.
A buyer may negotiate for:
- broader warranties;
- longer warranty periods;
- consequential damages;
- service commitments;
- or performance guarantees.
Warranty law therefore interacts closely with contract drafting and commercial risk allocation.
25. Breach of Warranty
A warranty creates an obligation.
If the goods fail to conform to the warranty, the buyer may have a claim for breach of warranty.
For example:
Seller warrants that the equipment can process 1,000 units per hour.
The buyer purchases the equipment.
The equipment can process only 500 units per hour under the circumstances covered by the warranty.
The buyer may argue that the seller breached an express warranty.
Similarly, a defective product may violate an implied warranty of merchantability.
A product unsuitable for the buyer’s communicated special purpose may violate an implied warranty of fitness.
26. Warranty Breach vs. Fraud
A warranty claim should not automatically be confused with fraud.
Suppose a seller falsely states:
“This vehicle has never been in an accident.”
That statement may create an express warranty.
If it is false, the buyer may have a warranty claim.
But if the seller knowingly lied with fraudulent intent, additional legal theories may potentially arise.
The same factual conduct can sometimes support multiple causes of action.
The distinction matters because the elements and remedies of warranty, fraud, negligent misrepresentation, and other claims can differ.
27. Warranty vs. Negligence
A warranty claim is generally contractual in nature.
The central question is whether the goods conformed to the contractual warranty.
Negligence asks a different question:
Did the defendant fail to exercise the required level of reasonable care?
The same defective product can potentially give rise to both contractual and tort theories, depending on the facts and applicable law.
The theories should therefore not be automatically merged.
28. Remedies for Breach of Warranty
When a warranty is breached, the buyer may have remedies available under Article 2.
Depending on the circumstances, these can include:
- damages;
- damages based on the difference between the value of the goods as warranted and their actual value;
- incidental damages;
- consequential damages;
- rejection in appropriate circumstances;
- revocation where statutory requirements are satisfied;
- or other remedies recognized by Article 2.
The precise remedy depends on:
- the nature of the breach;
- the buyer’s conduct;
- the seller’s opportunity to cure;
- contractual limitations;
- and applicable UCC provisions.
Warranty law therefore cannot be separated entirely from the broader Article 2 remedies framework.
29. Limitations of Remedies
Commercial contracts sometimes attempt to limit the buyer’s remedy.
For example:
“Seller’s sole obligation is to repair or replace defective goods.”
Such provisions can be enforceable in appropriate circumstances.
But UCC Article 2 imposes rules concerning limitations of remedies, including circumstances in which an exclusive remedy may fail of its essential purpose.
Therefore, a warranty dispute may involve two separate questions:
- Was there a breach of warranty?
- What remedy is contractually and legally available for that breach?
These questions should be analyzed separately.
30. A Practical Example
Suppose a restaurant purchases a commercial refrigerator.
The seller makes three representations:
- The refrigerator maintains temperatures between 34°F and 38°F.
- It is designed for continuous commercial use.
- It is suitable for storing highly perishable food.
The restaurant purchases the refrigerator.
After installation, the refrigerator repeatedly reaches 45°F.
Several warranty questions arise.
Express warranty
The specific temperature representation may create an express warranty.
Merchantability
If the seller is a merchant dealing in commercial refrigeration equipment, the refrigerator may also be subject to an implied warranty of merchantability.
Fitness
If the restaurant specifically explained its need to store highly perishable food and relied on the seller’s recommendation, an implied warranty of fitness for a particular purpose may also arise.
Breach
If the refrigerator cannot maintain the promised temperature, the buyer may have one or more warranty claims.
Remedy
The parties’ contract may specify repair, replacement, refund, or another remedy, subject to applicable UCC limitations.
One transaction can therefore involve several overlapping warranty theories.
31. How to Analyze a UCC Warranty Problem
A systematic approach is useful.
Step 1: Confirm Article 2 applies
Determine whether the transaction involves the sale of goods.
Step 2: Identify the alleged warranty
Ask whether the buyer relies on:
- an express warranty;
- merchantability;
- fitness for a particular purpose;
- course of dealing;
- usage of trade;
- or another applicable warranty.
Step 3: Identify how the warranty arose
For an express warranty, identify the statement, description, sample, or model.
For merchantability, determine whether the seller is a merchant with respect to the goods.
For fitness, determine what the seller knew about the buyer’s purpose and reliance.
Step 4: Determine the scope
What exactly did the warranty promise?
Step 5: Determine whether the goods conformed
Compare the actual goods with the warranty.
Step 6: Examine disclaimers
Did the contract attempt to exclude or modify the warranty?
Step 7: Examine remedy limitations
What contractual or statutory remedies are available?
Step 8: Consider defenses and other legal theories
Depending on the facts, issues involving inspection, notice, fraud, negligence, limitation periods, or other doctrines may arise.
32. Common Misunderstandings
“A warranty exists only if the contract uses the word warranty.”
False.
An express warranty can arise from a factual affirmation, promise, description, sample, or model.
“Every statement by a salesperson is a warranty.”
Not necessarily.
Courts distinguish factual representations from opinions, puffery, and other non-actionable statements.
“Merchantability means the product must be excellent.”
No.
Merchantability generally requires fitness for ordinary purposes, not superior quality.
“Fitness for a particular purpose is the same as merchantability.”
No.
Merchantability concerns ordinary use. Fitness concerns a particular purpose communicated to the seller combined with the required knowledge and reliance.
“Only merchants can give warranties.”
No.
Express warranties can arise from a seller’s representations regardless of whether the seller qualifies as a merchant.
The implied warranty of merchantability, however, generally depends on merchant status.
“Saying ‘as is’ always eliminates every warranty.”
Not necessarily.
The effectiveness of disclaimers depends on statutory requirements, the type of warranty, the language used, and applicable law.
“A breach of warranty is automatically fraud.”
No.
Warranty and fraud are distinct legal theories with different elements.
33. The Deeper Principle Behind UCC Warranties
UCC warranty law reflects a fundamental idea:
A commercial transaction involves more than the transfer of possession. It involves the allocation of expectations and risks concerning the goods.
When a seller tells a buyer what a product is, what it can do, or what it is suitable for, those representations may become legally significant.
When a merchant sells ordinary goods, the law may impose minimum expectations concerning their quality and ordinary functionality.
And when a buyer communicates a special purpose and relies on the seller’s expertise, the law may place responsibility on the seller for providing suitable goods.
Warranties therefore perform an important economic function.
They allocate the risk of defective, unsuitable, or misdescribed goods between the parties.
34. Express Warranty vs. Implied Warranty
| Express Warranty | Implied Warranty |
|---|---|
| Created by statements, promises, descriptions, samples, or models | Created by operation of law |
| Can arise from seller’s representations | Can arise even when seller says nothing |
| Focuses on what was represented | Focuses on statutory or commercially implied expectations |
| Does not necessarily require merchant status | Merchantability generally requires a merchant seller |
| Can concern specific characteristics or performance | Merchantability concerns ordinary purposes |
| Fitness concerns a communicated particular purpose | Fitness can arise from seller’s knowledge and buyer’s reliance |
The distinction is essential because different warranties arise under different conditions.
35. Warranty Analysis in Modern Commerce
Modern commerce makes warranty issues increasingly complicated.
Goods may include:
- software;
- connected devices;
- sensors;
- artificial intelligence systems;
- embedded technology;
- digital components;
- subscription-based functionality;
- and continuously updated features.
A product may physically conform to its description while its software component fails.
This creates difficult questions about:
- what constitutes the “goods”;
- what the seller promised;
- whether a software feature is part of the bargain;
- whether updates affect conformity;
- and what warranty terms govern digital functionality.
Article 2 remains important, but modern transactions can require careful analysis of the interaction between goods, services, software, and other bodies of law.
Key Takeaways
- UCC warranties establish legally enforceable expectations concerning goods.
- Express warranties can arise from affirmations of fact, promises, descriptions, samples, or models.
- The seller does not necessarily need to use the word “warranty.”
- An express warranty generally concerns a representation that becomes part of the basis of the bargain.
- The implied warranty of merchantability generally applies when a merchant sells goods of the relevant kind.
- Merchantability means that goods are generally fit for their ordinary purposes.
- The implied warranty of fitness for a particular purpose concerns a special use communicated to the seller and the buyer’s reliance on the seller’s skill or judgment.
- Merchantability and fitness are distinct warranties and can exist simultaneously.
- Warranties may also be informed by course of dealing and usage of trade.
- UCC § 2-316 governs important aspects of warranty disclaimers and modifications.
- “As is” and “with all faults” language can exclude implied warranties in appropriate circumstances.
- Breach of warranty is generally a contractual problem, although other legal theories may arise from the same conduct.
- Warranty disputes require separate analysis of creation, scope, breach, defenses, disclaimers, and remedies.
Frequently Asked Questions
What are UCC warranties?
UCC warranties are legally enforceable promises or implied obligations concerning goods sold under Article 2.
What are the main types of UCC warranties?
The principal categories are express warranties, implied warranty of merchantability, and implied warranty of fitness for a particular purpose.
Does an express warranty have to use the word “warranty”?
No. A factual affirmation, promise, description, sample, or model can create an express warranty when it becomes part of the basis of the bargain.
What is the implied warranty of merchantability?
It is a statutory warranty that generally requires goods sold by a merchant to be fit for their ordinary purposes and to satisfy other requirements of merchantability.
What is the warranty of fitness for a particular purpose?
It is an implied warranty that may arise when the seller knows the buyer’s particular purpose and knows the buyer is relying on the seller’s skill or judgment in selecting suitable goods.
Can a seller disclaim an implied warranty?
Yes, in appropriate circumstances, but UCC § 2-316 imposes specific requirements concerning the language and presentation of disclaimers.
Does “as is” eliminate express warranties?
Not automatically. Express warranty language and disclaimer language must be analyzed together, and conflicting provisions may raise questions of statutory interpretation and contractual construction.
Can a buyer sue for breach of warranty if the product is defective?
Potentially, yes. The buyer must establish the applicable warranty, its scope, the product’s nonconformity, and any applicable defenses, limitations, and remedy provisions.
Is breach of warranty the same as negligence?
No. Warranty claims generally arise from contractual obligations, while negligence focuses on the failure to exercise reasonable care.
Why are warranties important under the UCC?
They allocate responsibility for the quality, characteristics, performance, and suitability of goods and provide buyers with legally enforceable expectations concerning what they purchased.
Conclusion
UCC warranty law provides the legal framework for determining what sellers have promised about goods and what buyers are entitled to expect from commercial transactions.
Some obligations arise because the seller said something.
Others arise because the law treats certain promises as existing even when the seller said nothing.
Express warranties protect buyers against false or unfulfilled representations concerning the goods. The implied warranty of merchantability establishes a baseline expectation that goods sold by qualifying merchants will be suitable for their ordinary purposes. The implied warranty of fitness for a particular purpose protects buyers who communicate a special need and reasonably rely on the seller’s expertise.
The law also permits parties to allocate risk through warranty disclaimers and remedy limitations, subject to the requirements of Article 2.
The central lesson is therefore not simply that “goods have warranties.”
It is that the law uses warranties to translate commercial expectations into legally enforceable obligations.
When analyzing a UCC warranty problem, the essential questions are:
- What warranty is alleged?
- How was it created?
- What exactly did it promise?
- Did the goods conform to that promise?
- Was the warranty effectively disclaimed or modified?
- What remedy is available for the breach?
Once those questions are separated, UCC warranty law becomes much easier to understand.
The warranty is ultimately about the same fundamental issue at the heart of commercial contracting:
What did the buyer have a legal right to expect when the transaction was made?
The information provided in this article ("UCC Warranties: Express and Implied Warranties in the Sale of Goods") is for general educational and informational purposes only and does not constitute formal legal advice. Reading this content does not create an attorney-client relationship. Laws vary by jurisdiction; consult a licensed attorney for specific legal matters.
Tsvety, LL.M., M.A.
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