A New York law that requires advance warning before enforcing automatic renewal provisions of many contracts applies to a doctor’s contract with a company for billing and other services, a state appeals panel has ruled, reversing a lower court judge.

The unanimous Appellate Division, First Department panel ruled Tuesday in Healthcare IQ LLC v. Chao, 108230/10, that the contract, between doctor Tsai Chung Chao and healthcare data management company Healthcare IQ, falls under General Obligations Law §5-903 because it involves “personal property” in the form of patient records.

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