We have previously reported regarding defense efforts to forestall class actions by offering to pay the class representative the value of the representative’s individual claim.  Prior attempts have involved Rule 68 Offers of Judgment or Rule 67 payments to court registries.  In Laurens v. Volvo Cars of North America, LLC, 868 F.3d 622 (7th Cir. 2017) (No. 16-3829), the Seventh Circuit held that an unaccepted offer of relief before a putative plaintiff files a class action lawsuit does not deprive the plaintiff of standing.  Relying on contract principles, the court held that unaccepted offers are not binding.  Expressing frustration with efforts to moot class actions, the court held that “while the legal effect of every variation on the strategic-mooting theme has not yet been explored, we are satisfied that an unaccepted pre-litigation offer does not deprive a plaintiff of her day in court.”  Notwithstanding the unaccepted offer, plaintiff could allege an injury in fact.