By a 6-3 decision in Campbell-Ewald Co. v. Gomez, No. 14-857 (U.S. 2016), the U.S. Supreme Court held that a settlement offer for complete relief does not moot a plaintiff’s case. In this case, the respondent (Gomez) filed a putative class action against the petitioner (Campbell) in California, alleging that Campbell violated the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A)(iii), in connection with contract work for the U.S. Navy. Gomez claimed he received unsolicited text messages from Campbell, which had been sent to over 100,000 recipients via a subcontractor, for which he sought the treble statutory damages allowed for willful and knowing violations of the TCPA. Prior to class certification, Campbell offered to settle with Gomez for the amount of his costs and to satisfy his own treble-damages claim, and filed an offer of judgment under Fed. R. Civ. P. 68. After Gomez did not accept the offer during the 14-day window specified in Rule 68, Campbell moved to dismiss the case, arguing that the offer to provide complete relief to Gomez mooted the claim. The district court denied the motion, but later granted summary judgment for Campbell on the basis of sovereign immunity derived from the Navy. On appeal, the Ninth Circuit vacated the summary judgment based on sovereign immunity, and agreed that the offer did not render the claim moot. At the Supreme Court, the majority opinion and Justice Thomas’s concurrence concluded that an offer of complete relief is insufficient to moot the claim. The majority reasoned that the offer loses any efficacy once rejected; the concurrence, however, relied on the law of tender, reasoning that “a mere offer” is not enough to end the case.