9th Circ. Says RJ Reynolds Promotion May Count As Contract

Law360, Los Angeles (May 7, 2012, 7:47 PM EDT) -- A Ninth Circuit judge expressed doubts Monday that a district court had properly dismissed a class action over R.J. Reynolds Tobacco Co.'s decision to stop honoring Camel cigarette “C-Notes,” saying the customer rewards program appeared to go beyond mere advertising to create a contract with consumers.

“Each customer enrolled in this program by sending in a C-Note and getting a number, and then got a catalog. They bought Camel cigarettes on the assumption there was a rewards program, correct?” U.S. Circuit Judge Raymond Fisher said. “There...
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