I respectfully dissent because, while I agree with the majority that this Court should look to the United States Supreme Court decision in Fleisher Engineering & Construction Co v *395United States ex rel Hallenbeck, 311 US 15; 61 S Ct 81; 85 L Ed 12 (1940), for guidance in the instant matter, I disagree with the majority’s interpretation and application of Fleisher to the facts of the instant case. This case presents us with the issue whether the failure to comply with the written notice by certified mail requirement of MCL 129.207; MSA 5.2321(7) precludes a subcontractor from recovering on a public works payment bond. I would hold that pursuant to MCL 129.207; MSA 5.2321(7), a claimant must send, and the principal contractor must receive, timely written notice by certified mail. Moreover, I would hold that Fleisher only excuses compliance with the certified mail requirement when a genuine issue of material fact does not exist regarding the issue whether the principal contractor received timely written notice under the payment bond statute. Thus, I would affirm the result reached by the Court of Appeals.
i
The United States Supreme Court decision in Fleisher involved the interpretation of the Miller Act, 40 USC 270b, the federal counterpart of MCL 129.207; MSA 5.2321(7).1 In Fleisher, the United *396States brought suit on behalf of a subcontractor to recover on a payment bond given by the defendant. The United States Supreme Court addressed the issue whether a claimant must prove receipt of written notice by certified mail, or whether actual receipt would suffice under the notice provision of the Miller Act. The defendant conceded that it received notice by regular mail. The Court distinguished between "conditions precedent to suit” and those additional requirements which guarantee that a party complies with the conditions precedent under the statute. The Court concluded that certified mail was not a condition precedent because it only served to substantiate that the principal contractor actually received written notice. The Court construed the act liberally because Congress enacted the act to provide relief for materialmen. Therefore, when the defendant conceded that it received written notice, but contended that the written notice failed to comply with the technical requirement that notice be served by certified mail, 2 it defied logic and common sense to deny recovery to the subcontractor. As the Court stated:
We think that the purpose of this provision [notice by certified mail requirement] as to manner of service was to assure receipt of the notice, not to make the described method mandatory so as to deny right of suit when the required written notice within the speciñed time had actually been given and received. In the face of such receipt, the reason for a particular mode of service fails. It is not reasonable to suppose that Congress intended *397to insist upon an idle form. Rather, we think that Congress intended to provide a method which would afford sufficient proof of service when receipt of the required written notice was not shown. [Fleisher, supra at 19. Emphasis added.]
I agree and believe that Fleisher requires the subcontractor to prove that the principal contractor received written notice within the time prescribed by the statute and not merely that the principal contractor had notice. In my opinion, Fleisher only excuses compliance with the certifíed mail requirement when a genuine issue of material fact does not exist regarding whether the principal contractor received written notice within the time prescribed by the payment bond statute.
ii
Initially, I agree with the majority that United States Supreme Court, federal court, and Michigan Supreme Court decisions decided after Fleisher have interpreted either the notice provision of the Miller Act or MCL 129.207; MSA 5.2321(7) as requiring compliance with four prerequisites.3 I agree with the majority as to the substance of the second,4 third, and fourth elements. However, I disagree with the majority’s recitation of the first element and its application to the facts of the instant case._
*398With regard to the third element, I agree that the claimant must send written notice. In People ex rel F Yeager Bridge & Culvert Co v Cooke Contracting Co, 372 Mich 563; 127 NW2d 308 (1964), this Court denied recovery to a claimant that did not send written notice. As this Court noted, "[m]ere knowledge by a surety that a certain party had furnished materials is insufficient notice.” Id. at 565. See also Charles W Anderson Co v Argonaut Ins Co, 62 Mich App 650; 233 NW2d 691 (1975). Moreover, numerous federal decisions also have interpreted the Miller Act and Fleisher as requiring written notice. United States ex rel Fordham v P W Parker, Inc, 504 F Supp 1066, 1070, n 3 (D Md, 1980); United States ex rel Joseph T Richardson, Inc v EJT Construction Co, Inc, 453 F Supp 435, 441, n 8 (D Del, 1978); United States ex rel Excavation Construction, Inc v Glenn-Stewart-Pinckney Builders & Developers, Inc, 388 F Supp 289, 296-297 (D Del, 1975); cf. United States ex rel Field & Associates, Inc v Globe Indemnity Co, 223 F Supp 121 (SD Ohio, 1962); United States ex rel Tecot Electric Supply Co v New Amsterdam Casualty Co, 185 F Supp 316 (ED Pa, 1960); United States ex rel Old Dominion Iron & Steel Corp v Massachusetts Bonding & Ins Co, 272 F2d 73 (CA 3, 1959) (actual notice received by the general contractor from an extraneous or third party was insufficient). As the Glenn-Stewart court stated:
The purpose for the statutory requirement that the notice be in writing is to prevent misunderstanding between the parties and to afford certain minimal evidence of communication between the parties. Coffee v United States [ex rel Gordon], 157 F2d 968, 969 (CA 5, 1946) and Apache Powder Co v Ashton Co, 264 F2d 417, 421 (CA 9, 1959). Hence, the elimination of a requirement of any written *399form of notice in a case where the receipt and content of notice is disputed would tend to emasculate the clear intent of the statute to avoid such disputes. See United States [ex rel Charles R Joyce & Sons, Inc] v F A Baehner, Inc, 326 F2d 556, 558 (CA 2, 1964).
Excavation argues that Mallory’s testimony provides undisputed evidence that sufficient timely notice was given and that a written notice supplementing Mallory’s testimony became unnecessary. Even if the Court were able to disregard the persuasive list of cases cited above which hold that written notice is a strict condition precedent to bringing suit under the Act, the Court would nevertheless reject Excavation’s argument. In this case written notice would confirm or deny Mallory’s supposition that she was told the amount of the Feinman bill. Written notice would evidence the nature of the communication and shed light on the context in which any information about the claim was given. It would indicate whether or not Mallory was justified in her conclusion that the telephonic conversation was intended merely as an effort by Garner to solicit Glenn-Stewart’s aid in Excavation’s attempts to contact Feinman and could in no possible way be interpreted as notice to Glenn-Stewart of a materialman’s and supplier’s claim. Thus, even without meeting Excavation’s argument that the notice need not indicate an intent by the use plaintiff to look to the defendant for payment, written notice serves a useful purpose. Of course, if articulation of such intent were found to be required, written notice would serve the additional purpose of supplying notice or lack of notice of such intent.
[7] Finally, a number of courts have expressly rejected Excavation’s argument that all the statute requires with respect to notice is that the general contractor have knowledge of the claim regardless of how that knowledge is acquired. In Bowden [v United States ex rel Malloy], 239 F2d [572,] 577 [(CA 9, 1956),] the use plaintiff argued that since a letter from a subcontractor to a gen*400eral contractor gave the general contractor all the information which it would have obtained if the use plaintiff had given the general contractor the written notice required by statute. The court rejected this "knowledge of the general contractor” theory stating:
"no rule of liberality in construction can justify reading out of the statute the very condition which Congress laid down as prerequisite to the cause of action” at 577.
I agree. The claimant must send notice in writing.
I also concur with the majority’s recitation of the fourth element, specifically, that the claimant must send timely written notice. In People ex rel Wheeling Corrugating Co v W L Thon Co, 307 Mich 273; 11 NW2d 886 (1943), this Court denied recovery to a claimant who conceded that it sent written notice after expiration of statutorily proscribed time limits of the notice provision. I agree. Timely written notice is a condition precedent under MCL 129.207; MSA 5.232K7).5
However, the issue in the instant case focuses upon this Court’s interpretation and application of the first element. The majority concludes the first element requires that "a claimant must prove that the principal contractor actually received notice.” Ante, p 382. According to the majority, even though the statute specifically requires a claimant to send "[e]ach notice ... by certified mail,” a claimant must only prove timely receipt of written notice. The majority contends that the Legislature *401enacted the certified mail requirement for the sole purpose of ensuring compliance with the statute’s more important condition, the written requirement. I do not agree with either the majority’s recitation of the first condition under the notice provision, or the majority’s application of this element to the facts of the instant case. I disagree for several reasons that this Court should ignore completely the statute’s directive that "notice shall be served by . . . certified mail . . . .”
First, while I agree that this Court should look to Fleisher for guidance in the instant case, I disagree with the extent to which the majority relies upon and expands Fleisher. In Fleisher, the United States Supreme Court excused the claimant’s compliance with the certified mail requirement because the principal contractor conceded that it had received timely written notice by regular mail. However, the Court never intimated that it intended to excise the certified mail requirement from the statute. I agree and decline to join the majority’s erasure of the certified mail requirement from MCL 129.207; MSA 5.2321(7).
Second, the majority justifies overlooking the certified mail requirement on the grounds that "[h]ad the Legislature desired a procedure whereby it could conclusively be established that defendant received plaintiff’s notice, it would have required notice be sent certified mail with return receipt requested.” Ante, p 386. I do not agree. This Court should not ignore a statutory requirement upon the basis of our belief that the Legislature could have placed more exacting language within a given statute.6_
*402Third, I disagree with the lack of importance the majority places upon the certified mail requirement. Unlike the majority, I believe the Legislature enacted each of the requirements in the payment bond statute for an equally important purpose. In this regard, the certified mail requirement serves two important functions: first, as recognized by the majority, to ensure timely receipt of written notice, and, second, to eliminate disputes between contractors and subcontractors over whether the subcontractor sent and the principal contractor received timely written notice. Thus, while I agree with the majority that each of the requirements under the payment bond statute has a "substantive purpose,” I disagree with the conclusion that the statute’s "timely” and "written” notice requirements are any more "substantive” than the certified mail requirement. I am persuaded that each serves an important purpose in ensuring that a principal contractor received notice. This Court should not arbitrarily ignore one prerequisite over another.
Fourth, the justification advocated by the majority for ignoring the certified mail requirement also supports an interpretation of the payment bond statute which the majority specifically rejected, namely, the statute only requires that "the principal contractor [had] notice.”7 The majority contends that, "the ultimate purpose of the public works bond act [is] the protection of subcontractors and suppliers of materials,” and therefore, this Court should ignore the "technical” certified mail requirement. However, if the majority correctly argues that this Court should overlook one statutory requirement in the interest of protecting subcontractors and materialmen, then it would *403seem to follow that this Court should ignore the other statutory conditions under the appropriate factual circumstances — anytime the claimant alleges that the principal contractor had notice. Otherwise, as the majority contends in rejecting the certified mail provision as a prerequisite to recovery under the payment bond statute, a principal contractor could avoid an otherwise valid claim solely because the claimant failed to notify the principal contractor through the proper medium. Rather than adopt an interpretation of the payment bond statute replete with inconsistencies, I prefer to adhere to an interpretation which considers and balances the importance of each statutory requirement.
Moreover, this Court’s primary goal in interpreting MCL 129.207; MSA 5.2321(7) is to give effect to the intent of the Legislature. As this Court stated in Dussia v Monroe Co Employees Retirement System, 386 Mich 244, 248; 191 NW2d 307 (1971):
The words of a statute, however, should not be construed in the void but must be read together to effectuate the intention of the legislature. . . . The general rule of statutory construction was stated by this Court in Grand Rapids v Crocker (1922), 219 Mich 178 [182-183; 189 NW 221]:
"There seems to be no lack of harmony in the rules governing the interpretation of statutes. All are agreed that the primary one is to ascertain and give effect to the intention of the legislature. All others serve but as guides to assist the courts in determining such intent with a greater degree of certainty. If the language employed in a statute is plain, certain and unambiguous, a bare reading suffices and no interpretation is necessary. The rule is no less elementary that effect must be given, if possible, to every word, sentence and section. To that end, the entire act must be read, and the interpretation to be given to a particular *404word in one section arrived at after due consideration of every other section so as to produce, if possible, a harmonious and consistent enactment as a whole.” [See also In re Forfeiture of $5,264, 432 Mich 242, 248; 439 NW2d 246 (1989).]
The legislative history of MCL 570.102; MSA 26.322, the predecessor of MCL 129.207; MSA 5.2321(7), indicates that as originally enacted a claimant only had to provide written notice before making a claim for payment. The act did not contain the additional thirty-day notice requirement at issue in the instant case. 1905 PA 187. In 1927, the Legislature amended the notice provision so as to require a claimant to provide written notice within sixty days from furnishing the last materials, supplies, or labor. The Legislature did not adopt the thirty-day provision. 1927 PA 167. However, in 1963, the Legislature not only increased the sixty-day written notice requirement to ninety days, but it also enacted the additional thirty-day written notice requirement and the requirement that the subcontractor furnish notice by certified mail. 1963 PA 213, MCL 129.207; MSA 5.2321(7). Thus, while on the one hand I agree that this Court should construe the act liberally because its overall salutary purpose is to protect subcontractors and materialmen, on the other hand, the evolution of the act and its unambiguous terms8 also evince a clear legislative intent to provide the principal contractor with more protections through the certified mail provision and the addition of the thirty-day notice requirement.9 Un*405like either the majority or concurring opinions,10 rather than ignore one competing objective at the expense of the other, I. prefer to strike an harmonious balance between the two.
Lastly, a comparison between notice provision of the Miller Act and MCL 129.207; MSA 5.2321(7) supports this conclusion. MCL 129.207; MSA 5.2321(7) differs from the Miller Act because the Miller Act permits notice by either registered mail or in any manner in which the United States Marshall is authorized to serve summons. On the one hand, I agree that we should look to the Fleisher and the Miller Act for guidance in the instant case. However, on the other hand, it is equally important to recognize that MCL 129.207; MSA 5.2321(7) provides a more stringent notice requirement that does not contemplate service by means other than certified mail. The Legislature presumably adopted the certified mail requirement to substantiate receipt of the written notice and, therefore, avoid disputes regarding whether the principal contractor received written notice.
Thus, while I agree with Fleisher that it makes little sense to adhere to the certified mail requirement when the contractor concedes it received written notice, it does not also follow that we should ignore completely the terms of the statute and require a trial on the merits every time a subcontractor contends that it sent timely written notice by means other than certified mail. I decline to adopt an interpretation of MCL 129.207; MSA 5.2321(7) that would emasculate the statute’s *406certified mail requirement and render it nugatory.11
in
Each of the cases interpreting the Miller Act or MCL 129.207; MSA 5.2321(7) addressed a slightly different facet of what constitutes a condition precedent under either act. I am persuaded that along with the legislative history of the notice provision, together, they lead to the conclusion that, in the absence of timely written notice by certified mail, the subcontractor must prove that it sent and the principal contractor actually received timely written notice. Unlike the majority, I disagree that the claimant can circumvent the certified mail requirement and survive a motion for summary disposition simply by alleging that it sent, and the principal contractor received, timely written notice. The issue before this Court, and before the trial court on motion for summary disposition, was not whether the principal contractor received the timely written notice, but rather, whether it received timely written notice by certified mail. I would hold that if a genuine issue of material fact exists regarding whether the principal contractor received written notice within the time period prescribed by the statute, the claimant cannot recover on the payment bond.
As applied in the instant case, although Pi-Con claims that it sent written notice by regular mail within thirty days, Anderson has continuously argued that it never received timely written notice. Moreover, Pi-Con has not submitted any other proof that Anderson received notice as required by *407MCL 129.207; MSA 5.2321(7). Under these circumstances, I would hold that Pi-Con cannot recover on the payment bond.12
iv
Accordingly, I would hold that pursuant to MCL 129.207; MSA 5.2321(7), a claimant must send, and the principal contractor must receive, timely written notice by certified mail. I also would hold that Fleisher excuses compliance with the certified mail requirement only when a genuine issue of material fact does not exist regarding the issue whether the principal contractor received timely written notice under the payment bond statute. I would affirm the result of the Court of Appeals.
Brickley and Boyle, JJ., concurred with Riley, C.J.These provisions are almost identical, except that the Miller Act only requires ninety-days’ notice from the date on which the claimant last provided labor or materials for which the claimant seeks reimbursement. 40 USC 270b(a) provides in pertinent part:
That any person having direct contractual relationship with a subcontractor but no contractual relationship express or implied with the contractor furnishing said payment bond shall have a right of action upon the said payment bond upon giving written notice to said contractor within ninety days from the date on which such person did or performed the last of the labor or furnished or supplied the last of the material for which such claim is made, stating with substantial accuracy the amount claimed and the name of the party to whom the *396material was furnished or supplied or for whom the labor was done or performed. Such notice shall be served by mailing the same by registered mail, ... or in any manner ....
The defendant also argued that the contents of the notice were inadequate. The Supreme Court did not address this issue.
The majority states that the statute requires that "[fjirst, a claimant must prove that the principal contractor actually received notice. Second, the notice must relate 'the nature of the materials being furnished or to be furnished, or labor being performed or to be performed and identify[ ] the party contracting for such labor or materials and the site for the performance of such labor or the delivery of such materials . . . .’ Third, the notice sent must have been written. Fourth, the notice must have been received within the time limits prescribed by the statute.” Ante, p 382.
The appeal in the instant case does not involve the second element. However, the parties should be allowed to address this issue at the trial on remand.
Furthermore, the federal decisions interpreting Fleisher and the Miller Act also require compliance with statutorüy proscribed time limitations. As the United States Court of Appeals for the First Circuit stated succinctly: "The requirement that notice must be given to the principal contractor within the ninety-day period is mandatory and is a strict condition precedent to the existence of any right of action upon the principal contractor’s bond. Fleisher Engineering & Construction Co v United States . . . .” United States ex rel John D Ahern Co, Inc v J F White Contracting, 649 F2d 29, 31 (CA 1, 1981).
Although the majority’s argument might be appropriate if it presented this argument to the Legislature in an effort to change the current statutory language, the argument does not address the issue before the Court today: specifically, whether a claimant must comply with the unambiguous terms of the payment bond statute.
Justice Levin’s separate opinion seems to adopt a variation of this interpretation of MCL 129.207; MSA 5.2321(7).
Neither the plaintiff nor the majority argue that the statute is ambiguous.
1 also find it significant that the Legislature has never withdrawn or attenuated the requirement that the subcontractor provide written notice.
For example, a careful review of the majority’s analysis reveals that it permits what the statute intended to eliminate — disputes between contractors and subcontractors over whether the contractor received timely written notice. Under the majority’s analysis, as long as the subcontractor alleges that it sent timely written notice, the case must proceed to trial because an issue of fact exists regarding whether the principal contractor received timely written notice.
Even under the Miller Act, the United States Supreme Court has held that the general salutary language of the act cannot override more specific provisions. Clifford F MacEvoy Co v United States ex rel Calvin Tomkins Co, 322 US 102; 64 S Ct 890; 88 L Ed 1163 (1944).
For example, in absence of Anderson’s admission that it received timely written notice, Pi-Con might have been able to prove receipt of timely written notice sufficient to avoid summary disposition if the mailgram sent by Anderson to Brian & Gregory on December 7,1982, acknowledged that Anderson received written notice from Pi-Con, and had not merely expressed concerns about the quality of Pi-Con’s workmanship.