North Dakota Code § 1-01-37

Written and printed - Definition
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The words "writing" and "written" include "typewriting" and "typewritten", and "printing" and 
"printed", except in the case of signatures and when the words are used by way of contrast to 
typewriting and printing. Writing may be made in any manner, except that when a person 
entitled to require the execution of writing demands that it be made with ink, it must be so made.

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