n7 Mattei involved an executory contract for the sale of land for a shopping center. The contract provided that the buyer's obligation to consummate the purchase was "subject to [the procurement] of leases satisfactory to the purchaser." 330 P.2d at 626. The seller-defendant contended that the presence of that clause vitiated the parties' contract by destroying the mutuality of their obligations. The court rejected the argument. In the process of justifying its conclusion that the buyer's obligation was not rendered illusory by this clause, it explained that courts had applied two standards in giving satisfaction clauses effect:

First, in those contracts where the condition calls for satisfaction as to commercial value or quality, operative fitness, or mechanical utility, dissatisfaction cannot be claimed arbitrarily, unreasonably, or capriciously . . . . and the standard of a reasonable person is used in determining whether satisfaction has been received . . . . However, it would seem that the factors involved in determining whether a lease is satisfactory to the lessor are too numerous and varied to permit the application of a reasonable man standard as envisioned by this line of cases. Illustrative of some of the factors which would have to be considered in this case are the duration of the leases, their provisions for renewal options, if any, their covenants and restrictions, the amounts of the rentals, the financial responsibility of the lessees, and the character of the lessees' business.

This multiplicity of factors which must be considered in evaluating a lease shows that this case more appropriately falls within the second line of authorities dealing with "satisfaction" clauses, being those involving fancy, taste, or judgment. Where the question is one of judgment, the promisor's determination that he is not satisfied, when made in good faith, has been held to be a defense to an action on the contract. 51 Cal. 2d 119, 330 P.2d 626-27 (citations omitted).

   The California Supreme Court recently reaffirmed its adherence to the Mattei rule . . .