As another example, in Maryland, under Meadowlark Insurance Company v. Insurance Commissioner of the State of Maryland, 101 Md. App. 379 (1994), “[i]f the contract at issue has been preceded by any communication (e.g., letters, phone calls, telegrams, facsimile transmission, short wave radio etc., etc.), either originating in Maryland or received in Maryland . . . it is not entitled to [the direct procurement] exemption . . . .” (Emphasis in original).
