On October 17, 2012, the U.S. Court of Appeals for the Ninth Circuit reversed a Washington federal trial court’s dismissal of the putative class action against Best Buy alleging violations of the Telephone Consumer Protection Act (TCPA). The plaintiffs alleged that Best Buy made automated calls encouraging consumers to visit a Best Buy store to redeem their “Reward Zone” points. The trial court held that the calls were informational and thus not an unlawful solicitation under TCPA. The Ninth Circuit used what it called “a measure of common sense” to reach the opposition conclusion: “Redeeming Reward Zone points required going to a Best Buy store and making further purchases of Best Buy’s goods. There was no other use for the Reward Zone points. Thus, the calls encouraged the listener to make future purchases at Best Buy.” The court of appeals reasoned that “(n)either the statute nor the [FCC’s] regulations require an explicit mention of a good, product or service where the implication is clear from the context.” The court further stated that “(a)ny additional information provided in the calls does not inoculate them.” Chesbro v. Best Buy Co., No. 11-35784 (9th Cir.).