. An acceptance with varying terms operates as a counter-offer. Restatement (2nd) of Contracts § 59.
. Restatement (2nd) §§ 30(2), 32, 62; UCC § 2-206.
. See UCC § 2-209.
. What about different--that is, contradictory--terms? See Northrop Corp. v. Litronic Industries, 29 F.3d 1173, 1175 (discussing three approaches). California courts treat different terms like additional ones. See Steiner v. Mobil Oil Corporation, 20 Cal. 3d 90, 101-02 (1977).
. Even if only by use of conflicting forms. See UCC § 2-207, Comment 6.
. But see Dorton v. Collins & Aikman Corp., 453 F.2d 1161, 1169 n. 6 (6th Cir. 1972) (approving trial court's comparison of oral offer and written acceptance).
 Compare C. Itoh & Co. (America) Inc. v. Jordan Int'l Co., 552 F.2d 1228, 1237 (7th Cir. 1977) (disallowing reintroduction of terms on which the parties' writings disagreed and limiting supplementary terms to gap-fillers like implied warranties) with Daitom, Inc. v. Pennwalt Corp., 741 F.2d 1569, 1580 (10th Cir. 1984) (admitting any supplementary terms provided by other provisions of the UCC, including terms provided by reference to course of performance, course of dealing, and custom).
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