Sateriale v. R.J. Reynolds Tobacco Company
United States Court of Appeals for the Ninth Circuit
697 F.3d 777 (9th Cir. 2012)
Relevant factsFree
R.J. Reynolds Tobacco Company (RJR) (defendant) ran a 'Camel Cash' loyalty program letting customers redeem certificates from cigarette packages for merchandise, then announced it was discontinuing the program and gave participants until March 2007 to redeem their certificates -- but stopped printing merchandise catalogs starting in October 2006 and told participants no merchandise was left. Sateriale and other participants (plaintiffs) who tried and failed to redeem certificates during that window sued RJR for breach of contract, and the trial court dismissed the suit for failure to state a claim.
IssueFree
Whether an advertisement can constitute an offer.