124671
: Reaffirming its own precedent (the Barber rule), the court held that an effective tender made before a class-certification motion is filed satisfies the individual claim and moots the interest in the litigation.
: The U.S. Supreme Court had previously ruled in Campbell-Ewald Co. v. Gomez that an unaccepted settlement offer does not make a case moot in federal court. 3. The Supreme Court's Decision 124671
: For plaintiffs in Illinois, filing a motion for class certification simultaneously with the complaint is now a common strategy to prevent a "pick-off" tender. : Reaffirming its own precedent (the Barber rule),