Some contracts, though, fall under what's called the "statute of frauds" - that means they must be written to become contracts. From the link you provide, it explains that the statue of frauds makes a contract voidable (either party can break it) but it's still a contract. Also: 'Sometimes, a party to a contract that would otherwise be invalid under a "statute of frauds" will nonetheless be able to enforce it, on the basis of "partial performance" or "promissory estoppel".' Seems TechCrunch can reasonably claim partial performance.