JOHN D.R. LEONARD, Plaintiff, -against- 

PEPSICO, INC. Defendant.

                      96 Civ. 5320(KMW), 96 Civ. 9069(KMW)

           UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT 
OF
                                    NEW YORK

                          1999 U.S. Dist. LEXIS 11987

                           August 4, 1999, Decided   
                             August 5, 1999, Filed

DISPOSITION:   [*1]   Defendant's motion for summary judgment 
granted. Any pending motions moot.  

COUNSEL: For PEPSICO, INC., plaintiff (96-CV-5320): David N. 
Wynn, Arent Fox Kintner Plotkin & Kahn, New York, NY.
 
For JOHN D.R. LEONARD, plaintiff (96-CV-9069): David E. Nachman, 
Solomon, Zauderer, Ellenhorn, Frischer & Sharp, New York, NY.
 
For PEPSICO, INC., defendant (96-CV-9069): David N. Wynn, Arent 
Fox Kintner Plotkin & Kahn, New York, NY.
 
For PEPSICO, INC., defendant (96-CV-9069): Charles D. Ossola, 
Arnold & Porter, Washington, DC.  

JUDGES: Kimba M. Wood, United States District Judge.  

OPINIONBY: Kimba M. Wood  

OPINION: OPINION & ORDER
 
WOOD, U.S.D.J.:  

   Plaintiff brought this action seeking, among other things, 
specific performance of an alleged offer of a Harrier Jet, 
featured in a television advertisement for defendant's "Pepsi 
Stuff" promotion. Defendant has moved for summary judgment 
pursuant to Federal Rule of Civil Procedure 56. For the reasons 
stated below, defendant's motion is granted.  

   I. Background  

   This case arises out of a promotional campaign conducted by 
defendant, the producer and distributor of the soft drinks Pepsi 
and Diet Pepsi. (See PepsiCo Inc.'s Rule 56.1 Statement ("Def. 
Stat.   [*2]   ") P 2.) n1 The promotion, entitled "Pepsi Stuff," 
encouraged consumers to collect "Pepsi Points" from specially 
marked packages of Pepsi or Diet Pepsi and redeem these points 
for merchandise featuring the Pepsi logo. (See id. PP 4, 8.) 
Before introducing the promotion nationally, defendant conducted 
a test of the promotion in the Pacific Northwest from October 
1995 to March 1996. (See id. PP 5-6.) A Pepsi Stuff catalog was 
distributed to consumers in the test market, including Washington 
State. (See id. P 7.) Plaintiff is a resident of Seattle, 
Washington. (See id. P 3.) While living in Seattle, plaintiff saw 
the Pepsi Stuff commercial (see id. P 22) that he contends 
constituted an offer of a Harrier Jet.
 
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   n1 The Court's recitation of the facts of this case is drawn 
from the statements of uncontested facts submitted by the parties 
pursuant to Local Civil Rule 56.1. The majority of citations are 
to defendant's statement of facts because plaintiff does not 
contest many of defendant's factual assertions. (See Plaintiff 
Leonard's Response to PepsiCo's Rule 56.1 Statement ("Pl. 
Stat.").) Plaintiff's disagreement with certain of defendant's 
statements is noted in the text.  

   In an Order dated November 24, 1997, in a related case (96 
Civ. 5320), the Court set forth an initial account of the facts 
of this case. Because the parties have had additional discovery 
since that Order and have crafted Local Civil Rule 56.1 
Statements and Counterstatements, the recitation of facts herein 
should be considered definitive.
 
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 [*3]   
 
A. The Alleged Offer  

   Because whether the television commercial constituted an offer 
is the central question in this case, the Court will describe the 
commercial in detail. The commercial opens upon an idyllic, 
suburban morning, where the chirping of birds in sun-dappled 
trees welcomes a paperboy on his morning route. As the newspaper 
hits the stoop of a conventional two-story house, the tattoo of a 
military drum introduces the subtitle, "MONDAY 7:58 AM." The 
stirring strains of a martial air mark the appearance of a well-
coiffed teenager preparing to leave for school, dressed in a 
shirt emblazoned with the Pepsi logo, a red-white-and-blue ball. 
While the teenager confidently preens, the military drumroll 
again sounds as the subtitle "T-SHIRT 75 PEPSI POINTS" scrolls 
across the screen. Bursting from his room, the teenager strides 
down the hallway wearing a leather jacket. The drumroll sounds 
again, as the subtitle "LEATHER JACKET 1450 PEPSI POINTS" 
appears. The teenager opens the door of his house and, unfazed by 
the glare of the early morning sunshine, puts on a pair of 
sunglasses. The drumroll then accompanies the subtitle "SHADES 
175 PEPSI POINTS." A voiceover then intones, [*4]   "Introducing 
the new Pepsi Stuff catalog," as the camera focuses on the cover 
of the catalog. (See Defendant's Local Rule 56.1 Stat., Exh. A 
(the "Catalog").) n2
 
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   n2 At this point, the following message appears at the bottom 
of the screen: "Offer not available in all areas. See details on 
specially marked packages."
 
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   The scene then shifts to three young boys sitting in front of 
a high school building. The boy in the middle is intent on his 
Pepsi Stuff Catalog, while the boys on either side are each 
drinking Pepsi. The three boys gaze in awe at an object rushing 
overhead, as the military march builds to a crescendo. The 
Harrier Jet is not yet visible, but the observer senses the 
presence of a mighty plane as the extreme winds generated by its 
flight create a paper maelstrom in a classroom devoted to an 
otherwise dull physics lesson. Finally, the Harrier Jet swings 
into view and lands by the side of the school building, next to a 
bicycle rack. Several students run for cover, and the velocity of 
the wind strips  [*5]   one hapless faculty member down to his 
underwear. While the faculty member is being deprived of his 
dignity, the voiceover announces: "Now the more Pepsi you drink, 
the more great stuff you're gonna get."  

   The teenager opens the cockpit of the fighter and can be seen, 
helmetless, holding a Pepsi. "Looking very pleased with himself," 
(Pl. Mem. at 3,) the teenager exclaims, "Sure beats the bus," and 
chortles. The military drumroll sounds a final time, as the 
following words appear: "HARRIER FIGHTER 7,000,000 PEPSI POINTS." 
A few seconds later, the following appears in more stylized 
script: "Drink Pepsi -- Get Stuff." With that message, the music 
and the commercial end with a triumphant flourish.  

   Inspired by this commercial, plaintiff set out to obtain a 
Harrier Jet. Plaintiff explains that he is "typical of the 'Pepsi 
Generation' . . . he is young, has an adventurous spirit, and the 
notion of obtaining a Harrier Jet appealed to him enormously." 
(Pl. Mem. at 3.) Plaintiff consulted the Pepsi Stuff Catalog. The 
Catalog features youths dressed in Pepsi Stuff regalia or 
enjoying Pepsi Stuff accessories, such as "Blue Shades" ("As if 
you need another reason to look forward to sunny days.   [*6]   
"), "Pepsi Tees" ("Live in 'em. Laugh in 'em. Get in 'em."), "Bag 
of Balls" ("Three balls. One bag. No rules."), and "Pepsi Phone 
Card" ("Call your mom!"). The Catalog specifies the number of 
Pepsi Points required to obtain promotional merchandise. (See 
Catalog, at rear foldout pages.) The Catalog includes an Order 
Form which lists, on one side, fifty-three items of Pepsi Stuff 
merchandise redeemable for Pepsi Points (see id. (the "Order 
Form")). Conspicuously absent from the Order Form is any entry or 
description of a Harrier Jet. (See id.) The amount of Pepsi 
Points required to obtain the listed merchandise ranges from 15 
(for a "Jacket Tattoo" ("Sew 'em on your jacket, not your arm.")) 
to 3300 (for a "Fila Mountain Bike" ("Rugged. All-terrain. 
Exclusively for Pepsi.")). It should be noted that plaintiff 
objects to the implication that because an item was not shown in 
the Catalog, it was unavailable. (See Pl. Stat. PP 23-26, 29.)  

   The rear foldout pages of the Catalog contain directions for 
redeeming Pepsi Points for merchandise. (See Catalog, at rear 
foldout pages.) These directions note that merchandise may be 
ordered "only" with the original Order Form. (  [*7]   See id.) 
The Catalog notes that in the event that a consumer lacks enough 
Pepsi Points to obtain a desired item, additional Pepsi Points 
may be purchased for ten cents each; however, at least fifteen 
original Pepsi Points must accompany each order. (See id.)  

   Although plaintiff initially set out to collect 7,000,000 
Pepsi Points by consuming Pepsi products, it soon became clear to 
him that he "would not be able to buy (let alone drink) enough 
Pepsi to collect the necessary Pepsi Points fast enough." 
(Affidavit of John D.R. Leonard, Mar. 30, 1999 ("Leonard Aff."), 
P 5.) Reevaluating his strategy, plaintiff "focused for the first 
time on the packaging materials in the Pepsi Stuff promotion," 
(id.,) and realized that buying Pepsi Points would be a more 
promising option. (See id.) Through acquaintances, plaintiff 
ultimately raised about $700,000. (See id. P 6.)
 
B. Plaintiff's Efforts to Redeem the Alleged Offer 

   On or about March 27, 1996, plaintiff submitted an Order Form, 
fifteen original Pepsi Points, and a check for $700,008.50. (See 
Def. Stat. P 36.) Plaintiff appears to have been represented by 
counsel at the time he mailed his check; the check is  [*8]   
drawn on an account of plaintiff's first set of attorneys. (See 
Defendant's Notice of Motion, Exh. B (first).) At the bottom of 
the Order Form, plaintiff wrote in "1 Harrier Jet" in the "Item" 
column and "7,000,000" in the "Total Points" column. (See id.) In 
a letter accompanying his submission, plaintiff stated that the 
check was to purchase additional Pepsi Points "expressly for 
obtaining a new Harrier jet as advertised in your Pepsi Stuff 
commercial." (See Declaration of David Wynn, Mar. 18, 1999 ("Wynn 
Dec."), Exh. A.)  

   On or about May 7, 1996, defendant's fulfillment house 
rejected plaintiff's submission and returned the check, 
explaining that:  

   The item that you have requested is not part of the Pepsi 
Stuff collection. It is not included in the catalogue or on the 
order form, and only catalogue merchandise can be redeemed under 
this program.  

   The Harrier jet in the Pepsi commercial is fanciful and is 
simply included to create a humorous and entertaining ad. We 
apologize for any misunderstanding or confusion that you may have 
experienced and are enclosing some free product coupons for your 
use.
 
(Wynn Aff. Exh. B (second).) Plaintiff's previous counsel 
responded  [*9]   on or about May 14, 1996, as follows:  

   Your letter of May 7, 1996 is totally unacceptable. We have 
reviewed the video tape of the Pepsi Stuff commercial . . . and 
it clearly offers the new Harrier jet for 7,000,000 Pepsi Points. 
Our client followed your rules explicitly. . . .  

   This is a formal demand that you honor your commitment and 
make immediate arrangements to transfer the new Harrier jet to 
our client. If we do not receive transfer instructions within ten 
(10) business days of the date of this letter you will leave us 
no choice but to file an appropriate action against Pepsi . . . .
 
(Wynn Aff., Exh. C.) This letter was apparently sent onward to 
the advertising company responsible for the actual commercial, 
BBDO New York ("BBDO"). In a letter dated May 30, 1996, BBDO Vice 
President Raymond E. McGovern, Jr., explained to plaintiff that:
 
I find it hard to believe that you are of the opinion that the 
Pepsi Stuff commercial ("Commercial") really offers a new Harrier 
Jet. The use of the Jet was clearly a joke that was meant to make 
the Commercial more humorous and entertaining. In my opinion, no 
reasonable person would agree with your analysis of the 
Commercial.   [*10]   
 
(Wynn Aff. Exh. A.) On or about June 17, 1996, plaintiff mailed a 
similar demand letter to defendant. (See Wynn Aff., Exh. D.)  

   Litigation of this case initially involved two lawsuits, the 
first a declaratory judgment action brought by PepsiCo in this 
district (the "declaratory judgment action"), and the second an 
action brought by Leonard in Florida state court (the "Florida 
action"). n3 PepsiCo brought suit in this Court on July 18, 1996, 
seeking a declaratory judgment stating that it had no obligation 
to furnish plaintiff with a Harrier Jet. That case was filed 
under docket number 96 Civ. 5320. In response to PepsiCo's suit 
in New York, Leonard brought suit in Florida state court on 
August 6, 1996, although this case had nothing to do with 
Florida. n4 That suit was removed to the Southern District of 
Florida in September 1996. In an Order dated November 6, 1996, 
United States District Judge James Lawrence King found that, 
"Obviously this case has been filed in a forum that has no 
meaningful relationship to the controversy and warrants a 
transfer pursuant to 28 U.S.C. @ 1404(a)." Leonard v. PepsiCo, 
96-2555 Civ.-King, at 1 (S.D. Fla. Nov. 6, 1996).   [*11]   The 
Florida suit was transferred to this Court on December 2, 1996, 
and assigned the docket number 96 Civ. 9069.
 
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   n3 Because Leonard and PepsiCo were each plaintiff in one 
action and defendant in the other, the Court will refer to the 
parties as "Leonard" and "PepsiCo," rather than plaintiff and 
defendant, for its discussion of the procedural history of this 
litigation.  

   n4 The Florida suit alleged that the commercial had been shown 
in Florida. Not only was this assertion irrelevant, in that 
plaintiff had not actually seen the commercial in Florida, but it 
later proved to be false. See Leonard v. PepsiCo, 96-2555 Civ.-
King, at 1 (S.D. Fla. Nov. 6, 1996) ("The only connection this 
case has to this forum is that Plaintiff's lawyer is in the 
Southern District of Florida.").
 
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   Once the Florida action had been transferred, Leonard moved to 
dismiss the declaratory judgment action for lack of personal 
jurisdiction. In an Order dated November 24, 1997, the Court 
granted the motion to dismiss for lack of personal [*12]   
jurisdiction in case 96 Civ. 5320, from which PepsiCo appealed. 
Leonard also moved to voluntarily dismiss the Florida action. 
While the Court indicated that the motion was proper, it noted 
that PepsiCo was entitled to some compensation for the costs of 
litigating this case in Florida, a forum that had no meaningful 
relationship to the case. (See Transcript of Proceedings Before 
Hon. Kimba M. Wood, Dec. 9, 1997, at 3.) In an Order dated 
December 15, 1997, the Court granted Leonard's motion to 
voluntarily dismiss this case without prejudice, but did so on 
condition that Leonard pay certain attorneys' fees.  

   In an Order dated October 1, 1998, the Court ordered Leonard 
to pay $88,162 in attorneys' fees within thirty days. Leonard 
failed to do so, yet sought nonetheless to appeal from his 
voluntary dismissal and the imposition of fees. In an Order dated 
January 5, 1999, the Court noted that Leonard's strategy was 
"'clearly an end-run around the final judgment rule.'" (Order at 
2 (quoting Palmieri v. DeFaria, 88 F.3d 136 (2d Cir. 1996)).) 
Accordingly, the Court ordered Leonard either to pay the amount 
due or withdraw his voluntary dismissal, as well as his appeals 
therefrom,   [*13]   and continue litigation before this Court. 
(See Order at 3.) Rather than pay the attorneys' fees, Leonard 
elected to proceed with litigation, and shortly thereafter 
retained present counsel. 

   On February 22, 1999, the Second Circuit endorsed the parties' 
stipulations to the dismissal of any appeals taken thus far in 
this case. Those stipulations noted that Leonard had consented to 
the jurisdiction of this Court and that PepsiCo agreed not to 
seek enforcement of the attorneys' fees award. With these issues 
having been waived, PepsiCo moved for summary judgment pursuant 
to Federal Rule of Civil Procedure 56. The present motion thus 
follows three years of jurisdictional and procedural wrangling.  

   II. Discussion
 
A. The Legal Framework  

   1. Standard for Summary Judgment  

   On a motion for summary judgment, a court "cannot try issues 
of fact; it can only determine whether there are issues to be 
tried." Donahue v. Windsor Locks Bd. of Fire Comm'rs, 834 F.2d 
54, 58 (2d Cir. 1987) (citations and internal quotation marks 
omitted). To prevail on a motion for summary judgment, the moving 
party therefore must show that there are no such genuine issues 
of material  [*14]   fact to be tried, and that he or she is 
entitled to judgment as a matter of law. See Fed. R. Civ. P. 
56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322, 91 L. Ed. 2d 
265, 106 S. Ct. 2548 (1986); Citizens Bank v. Hunt, 927 F.2d 707, 
710 (2d Cir. 1991). The party seeking summary judgment "bears the 
initial responsibility of informing the district court of the 
basis for its motion," which includes identifying the materials 
in the record that "it believes demonstrate the absence of a 
genuine issue of material fact." Celotex Corp., 477 U.S. at 323.  

   Once a motion for summary judgment is made and supported, the 
non-moving party must set forth specific facts that show that 
there is a genuine issue to be tried. See Anderson v. Liberty 
Lobby, Inc., 477 U.S. 242, 251-52, 91 L. Ed. 2d 202, 106 S. Ct. 
2505 (1986). Although a court considering a motion for summary 
judgment must view all evidence in the light most favorable to 
the non-moving party, and must draw all reasonable inferences in 
that party's favor, see Consarc Corp. v. Marine Midland Bank, 
N.A., 996 F.2d 568, 572 (2d Cir. 1993), the nonmoving party  
[*15]   "must do more than simply show that there is some 
metaphysical doubt as to the material facts." Matsushita Elec. 
Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586, 89 L. Ed. 2d 
538, 106 S. Ct. 1348 (1986). If, based on the submissions to the 
court, no rational fact-finder could find in the non-movant's 
favor, there is no genuine issue of material fact, and summary 
judgment is appropriate. See Anderson, 477 U.S. at 250.  

   The question of whether or not a contract was formed is 
appropriate for resolution on summary judgment. As the Second 
Circuit has recently noted, "Summary judgment is proper when the 
'words and actions that allegedly formed a contract [are] so 
clear themselves that reasonable people could not differ over 
their meaning.'" Krumme v. Westpoint Stevens, Inc., 143 F.3d 71, 
83 (2d Cir. 1998) (quoting Bourque v. FDIC, 42 F.3d 704, 708 (1st 
Cir. 1994)) (further citations omitted); see also Wards Co. v. 
Stamford Ridgeway Assocs., 761 F.2d 117, 120 (2d Cir. 1985) 
(summary judgment is appropriate in contract case where 
interpretation urged by non-moving party is not "fairly 
reasonable"). Summary [*16]   judgment is appropriate in such 
cases because there is "sometimes no genuine issue as to whether 
the parties' conduct implied a 'contractual 
understanding.'. . . . In such cases, 'the judge must decide the 
issue himself, just as he decides any factual issue in respect to 
which reasonable people cannot differ.'" Bourque, 42 F.3d at 708 
(quoting Boston Five Cents Sav. Bank v. Secretary of Dep't of 
Housing & Urban Dev., 768 F.2d 5, 8 (1st Cir. 1985)).  

   2. Choice of Law  

   The parties disagree concerning whether the Court should apply 
the law of the state of New York or of some other state in 
evaluating whether defendant's promotional campaign constituted 
an offer. Because this action was transferred from Florida, the 
choice of law rules of Florida, the transferor state, apply. See 
Ferens v. John Deere Co., 494 U.S. 516, 523-33, 108 L. Ed. 2d 
443, 110 S. Ct. 1274 (1990). Under Florida law, the choice of law 
in a contract case is determined by the place "where the last act 
necessary to complete the contract is done." Jemco, Inc. v. 
United Parcel Serv., Inc., 400 So. 2d 499, 500-01 (Fla. Dist. Ct. 
App. 1981); see also   [*17]    Shapiro v. Associated Int'l Ins. 
Co., 899 F.2d 1116, 1119 (11th Cir. 1990).  

   The parties disagree as to whether the contract could have 
been completed by plaintiff's filling out the Order Form to 
request a Harrier Jet, or by defendant's acceptance of the Order 
Form. If the commercial constituted an offer, then the last act 
necessary to complete the contract would be plaintiff's 
acceptance, in the state of Washington. If the commercial 
constituted a solicitation to receive offers, then the last act 
necessary to complete the contract would be defendant's 
acceptance of plaintiff's Order Form, in the state of New York. 
The choice of law question cannot, therefore, be resolved until 
after the Court determines whether the commercial was an offer or 
not. The Court agrees with both parties that resolution of this 
issue requires consideration of principles of contract law that 
are not limited to the law of any one state. Most of the cases 
cited by the parties are not from New York courts. As plaintiff 
suggests, the questions presented by this case implicate 
questions of contract law "deeply ingrained in the common law of 
England and the States of the Union." (Pl. Mem. at 8.)
 
B.   [*18]   Defendant's Advertisement Was Not An Offer  

   1. Advertisements as Offers  

   The general rule is that an advertisement does not constitute 
an offer. The Restatement (Second) of Contracts explains that:
 
Advertisements of goods by display, sign, handbill, newspaper, 
radio or television are not ordinarily intended or understood as 
offers to sell. The same is true of catalogues, price lists and 
circulars, even though the terms of suggested bargains may be 
stated in some detail. It is of course possible to make an offer 
by an advertisement directed to the general public (see @ 29), 
but there must ordinarily be some language of commitment or some 
invitation to take action without further communication.
 
Restatement (Second) of Contracts @ 26 cmt. b (1979). Similarly, 
a leading treatise notes that:
 
It is quite possible to make a definite and operative offer to 
buy or sell goods by advertisement, in a newspaper, by a 
handbill, a catalog or circular or on a placard in a store 
window. It is not customary to do this, however; and the 
presumption is the other way. . . . Such advertisements are 
understood to be mere requests to consider and examine and 
negotiate;   [*19]   and no one can reasonably regard them as 
otherwise unless the circumstances are exceptional and the words 
used are very plain and clear.
 
1 Arthur Linton Corbin & Joseph M. Perillo, Corbin on Contracts @ 
2.4, at 116-17 (rev. ed. 1993) (emphasis added); see also 1 E. 
Allan Farnsworth, Farnsworth on Contracts @ 3.10, at 239 (2d ed. 
1998); 1 Samuel Williston & Richard A. Lord, A Treatise on the 
Law of Contracts @ 4:7, at 286-87 (4th ed. 1990). New York courts 
adhere to this general principle. See Lovett v. Frederick Loeser 
& Co., 124 Misc. 81, 207 N.Y.S. 753, 755 (Mun. Ct. N.Y. City 
1924) (noting that an "advertisement is nothing but an invitation 
to enter into negotiations, and is not an offer which may be 
turned into a contract by a person who signifies his intention to 
purchase some of the articles mentioned in the advertisement"); 
see also Geismar v. Abraham & Straus, 109 Misc. 2d 495, 439 
N.Y.S.2d 1005, 1006 (Dist. Ct. Suffolk Cty. 1981) (reiterating 
Lovett rule); People v. Gimbel Bros. Inc., 202 Misc. 229, 115 
N.Y.S.2d 857, 858 (Ct. Spec. Sess. 1952) (because an 
"advertisement does not constitute an  [*20]   offer of sale but 
is solely an invitation to customers to make an offer to 
purchase," defendant not guilty of selling property on Sunday).  

   An advertisement is not transformed into an enforceable offer 
merely by a potential offeree's expression of willingness to 
accept the offer through, among other means, completion of an 
order form. In Mesaros v. United States, 845 F.2d 1576 (Fed. Cir. 
1988), for example, the plaintiffs sued the United States Mint 
for failure to deliver a number of Statue of Liberty 
commemorative coins that they had ordered. When demand for the 
coins proved unexpectedly robust, a number of individuals who had 
sent in their orders in a timely fashion were left empty-handed. 
See id. at 1578-80. The court began by noting the "well-
established" rule that advertisements and order forms are "mere 
notices and solicitations for offers which create no power of 
acceptance in the recipient." Id. at 1580; see also Foremost Pro 
Color, Inc. v. Eastman Kodak Co., 703 F.2d 534, 538-39 (9th Cir. 
1983) ("The weight of authority is that purchase orders such as 
those at issue here are not enforceable contracts until  [*21]   
they are accepted by the seller."); n5 Restatement (Second) of 
Contracts @ 26 ("A manifestation of willingness to enter a 
bargain is not an offer if the person to whom it is addressed 
knows or has reason to know that the person making it does not 
intend to conclude a bargain until he has made a further 
manifestation of assent."). The spurned coin collectors could not 
maintain a breach of contract action because no contract would be 
formed until the advertiser accepted the order form and processed 
payment. See 845 F.2d at 1581; see also Alligood v. Procter & 
Gamble, 72 Ohio App. 3d 309, 594 N.E.2d 668 (Ohio Ct. App. 1991) 
(finding that no offer was made in promotional campaign for baby 
diapers, in which consumers were to redeem teddy bear proof-of-
purchase symbols for catalog merchandise); Chang v. First 
Colonial Savings Bank, 242 Va. 388, 410 S.E.2d 928 (Va. 1991) 
(newspaper advertisement for bank settled the terms of the offer 
once bank accepted plaintiffs' deposit, notwithstanding bank's 
subsequent effort to amend the terms of the offer). Under these 
principles, plaintiff's letter of March 27, 1996, with the Order 
Form and the appropriate number [*22]   of Pepsi Points, 
constituted the offer. There would be no enforceable contract 
until defendant accepted the Order Form and cashed the check.
 
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   n5 Foremost Pro was overruled on other grounds by Hasbrouck v. 
Texaco, Inc., 842 F.2d 1034, 1041 (9th Cir. 1987), aff'd, 496 
U.S. 543, 110 L. Ed. 2d 492, 110 S. Ct. 2535 (1990). See Chroma 
Lighting v. GTE Products Corp., 111 F.3d 653, 657 (9th Cir. 
1997), cert. denied sub nom., Osram Sylvania Products, Inc. v. 
Von Der Ahe, 522 U.S. 943, 118 S. Ct. 357, 139 L. Ed. 2d 278 
(1997).
 
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   The exception to the rule that advertisements do not create 
any power of acceptance in potential offerees is where the 
advertisement is "clear, definite, and explicit, and leaves 
nothing open for negotiation," in that circumstance, "it 
constitutes an offer, acceptance of which will complete the 
contract." Lefkowitz v. Great Minneapolis Surplus Store, 251 
Minn. 188, 86 N.W.2d 689, 691 (Minn. 1957). In Lefkowitz,  [*23]   
defendant had published a newspaper announcement stating: 
"Saturday 9 AM Sharp, 3 Brand New Fur Coats, Worth to $100.00, 
First Come First Served $1 Each." 86 N.W.2d at 690. Mr. Morris 
Lefkowitz arrived at the store, dollar in hand, but was informed 
that under defendant's "house rules," the offer was open to 
ladies, but not gentlemen. See id. The court ruled that because 
plaintiff had fulfilled all of the terms of the advertisement and 
the advertisement was specific and left nothing open for 
negotiation, a contract had been formed. See id.; see also 
Johnson v. Capital City Ford Co., 85 So. 2d 75, 79 (La. Ct. App. 
1955) (finding that newspaper advertisement was sufficiently 
certain and definite to constitute an offer).  

   The present case is distinguishable from Lefkowitz. First, the 
commercial cannot be regarded in itself as sufficiently definite, 
because it specifically reserved the details of the offer to a 
separate writing, the Catalog. n6 The commercial itself made no 
mention of the steps a potential offeree would be required to 
take to accept the alleged offer of a Harrier Jet. The 
advertisement in Lefkowitz, in contrast, "identified the person 
who could  [*24]   accept." Corbin, supra, @ 2.4, at 119. See 
generally United States v. Braunstein, 75 F. Supp. 137, 139 
(S.D.N.Y. 1947) ("Greater precision of expression may be 
required, and less help from the court given, when the parties 
are merely at the threshold of a contract."); Farnsworth, supra, 
at 239 ("The fact that a proposal is very detailed suggests that 
it is an offer, while omission of many terms suggests that it is 
not."). n7 Second, even if the Catalog had included a Harrier Jet 
among the items that could be obtained by redemption of Pepsi 
Points, the advertisement of a Harrier Jet by both television 
commercial and catalog would still not constitute an offer. As 
the Mesaros court explained, the absence of any words of 
limitation such as "first come, first served," renders the 
alleged offer sufficiently indefinite that no contract could be 
formed. See Mesaros, 845 F.2d at 1581. "A customer would not 
usually have reason to believe that the shopkeeper intended 
exposure to the risk of a multitude of acceptances resulting in a 
number of contracts exceeding the shopkeeper's inventory." 
Farnsworth, supra, at 242. There was no such danger  [*25]   in 
Lefkowitz, owing to the limitation "first come, first served."
 
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   n6 It also communicated additional words of reservation: 
"Offer not available in all areas. See details on specially 
marked packages."  

   n7 The reservation of the details of the offer in this case 
distinguishes it from Payne v. Lautz Bros. & Co., 166 N.Y.S.2d 
844 (City Ct. Buffalo 1916). In Payne, a stamp and coupon broker 
purchased massive quantities of coupons produced by defendant, a 
soap company, and tried to redeem them for 4,000 round-trip 
tickets to a local beach. The court ruled for plaintiff, noting 
that the advertisements were "absolutely unrestricted. It 
contained no reference whatever to any of its previous 
advertising of any form." Id. at 848. In the present case, by 
contrast, the commercial explicitly reserved the details of the 
offer to the Catalog.
 
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   The Court finds, in sum, that the Harrier Jet commercial was 
merely an advertisement. The Court now turns to the line of cases 
upon which  [*26]   plaintiff rests much of his argument.  

   2. Rewards as Offers  

   In opposing the present motion, plaintiff largely relies on a 
different species of unilateral offer, involving public offers of 
a reward for performance of a specified act. Because these cases 
generally involve public declarations regarding the efficacy or 
trustworthiness of specific products, one court has aptly 
characterized these authorities as "prove me wrong" cases. See 
Rosenthal v. Al Packer Ford, 36 Md. App. 349, 374 A.2d 377, 380 
(Md. Ct. Spec. App. 1977). The most venerable of these precedents 
is the case of Carlill v. Carbolic Smoke Ball Co., 1 Q.B. 256 
(Court of Appeal, 1892), a quote from which heads plaintiff's 
memorandum of law: "If a person chooses to make extravagant 
promises . . . he probably does so because it pays him to make 
them, and, if he has made them, the extravagance of the promises 
is no reason in law why he should not be bound by them." Carbolic 
Smoke Ball, 1 Q.B. at 268 (Bowen, L.J.).  

   Long a staple of law school curricula, Carbolic Smoke Ball 
owes its fame not merely to "the comic and slightly mysterious 
object involved," A.W. Brian Simpson,   [*27]   Quackery and 
Contract Law: Carlill v. Carbolic Smoke Ball Company (1893), in 
Leading Cases in the Common Law 259, 281 (1995), but also to its 
role in developing the law of unilateral offers. The case arose 
during the London influenza epidemic of the 1890s. Among other 
advertisements of the time, for Clarke's World Famous Blood 
Mixture, Towle's Pennyroyal and Steel Pills for Females, Sequah's 
Prairie Flower, and Epp's Glycerine Jube-Jubes, see Simpson, 
supra, at 267, appeared solicitations for the Carbolic Smoke 
Ball. The specific advertisement that Mrs. Carlill saw, and 
relied upon, read as follows:
 
100 L reward will be paid by the Carbolic Smoke Ball Company to 
any person who contracts the increasing epidemic influenza, 
colds, or any diseases caused by taking cold, after having used 
the ball three times daily for two weeks according to the printed 
directions supplied with each ball. 1000 L is deposited with the 
Alliance Bank, Regent Street, shewing our sincerity in the 
matter.  

   During the last epidemic of influenza many thousand carbolic 
smoke balls were sold as preventives against this disease, and in 
no ascertained case was the disease contracted by those  [*28]   
using the carbolic smoke ball.
 
Carbolic Smoke Ball, 1 Q.B. at 256-57. "On the faith of this 
advertisement," id. at 257, Mrs. Carlill purchased the smoke ball 
and used it as directed, but contracted influenza nevertheless. 
n8 The lower court held that she was entitled to recover the 
promised reward.
 
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   n8 Although the Court of Appeals's opinion is silent as to 
exactly what a carbolic smoke ball was, the historical record 
reveals it to have been a compressible hollow ball, about the 
size of an apple or orange, with a small opening covered by some 
porous material such as silk or gauze. The ball was partially 
filled with carbolic acid in powder form. When the ball was 
squeezed, the powder would be forced through the opening as a 
small cloud of smoke. See Simpson, supra, at 262-63. At the time, 
carbolic acid was considered fatal if consumed in more than small 
amounts. See id. at 264.
 
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   Affirming the lower court's decision, Lord Justice Lindley 
began by  [*29]   noting that the advertisement was an express 
promise to pay L 100 in the event that a consumer of the Carbolic 
Smoke Ball was stricken with influenza. See id. at 261. The 
advertisement was construed as offering a reward because it 
sought to induce performance, unlike an invitation to negotiate, 
which seeks a reciprocal promise. As Lord Justice Lindley 
explained, "advertisements offering rewards . . . are offers to 
anybody who performs the conditions named in the advertisement, 
and anybody who does perform the condition accepts the offer." 
Id. at 262; see also id. at 268 (Bowen, L.J.). n9 Because Mrs. 
Carlill had complied with the terms of the offer, yet contracted 
influenza, she was entitled to L 100.
 
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   n9 Carbolic Smoke Ball includes a classic formulation of this 
principle: "If I advertise to the world that my dog is lost, and 
that anybody who brings the dog to a particular place will be 
paid some money, are all the police or other persons whose 
business it is to find lost dogs to be expected to sit down and 
write a note saying that they have accepted my proposal?" 
Carbolic Smoke Ball, 1 Q.B. at 270 (Bowen, L.J.).
 
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 [*30]    

   Like Carbolic Smoke Ball, the decisions relied upon by 
plaintiff involve offers of reward. In Barnes v. Treece, 15 Wash. 
App. 437, 549 P.2d 1152 (Wash. Ct. App. 1976), for example, the 
vice-president of a punchboard distributor, in the course of 
hearings before the Washington State Gambling Commission, 
asserted that, "'I'll put a hundred thousand dollars to anyone to 
find a crooked board. If they find it, I'll pay it.'" 549 P.2d at 
1154. Plaintiff, a former bartender, heard of the offer and 
located two crooked punchboards. Defendant, after reiterating 
that the offer was serious, providing plaintiff with a receipt 
for the punchboard on company stationery, and assuring plaintiff 
that the reward was being held in escrow, nevertheless repudiated 
the offer. See id. at 1154. The court ruled that the offer was 
valid and that plaintiff was entitled to his reward. See id. at 
1155. The plaintiff in this case also cites cases involving 
prizes for skill (or luck) in the game of golf. See Las Vegas 
Hacienda v. Gibson, 77 Nev. 25, 359 P.2d 85 (Nev. 1961) (awarding 
$5,000 to plaintiff, who successfully shot a hole-in-one); see 
also Grove v. Charbonneau Buick-Pontiac, Inc., 240 N.W.2d 853 
(N.D. 1976)  [*31]   (awarding automobile to plaintiff, who 
successfully shot a hole-in-one).  

   Other "reward" cases underscore the distinction between 
typical advertisements, in which the alleged offer is merely an 
invitation to negotiate for purchase of commercial goods, and 
promises of reward, in which the alleged offer is intended to 
induce a potential offeree to perform a specific action, often 
for noncommercial reasons. In Newman v. Schiff, 778 F.2d 460 (5th 
Cir. 1985), for example, the Fifth Circuit held that a tax 
protestor's assertion that, "If anybody calls this show . . . and 
cites any section of the code that says an individual is required 
to file a tax return, I'll pay them $100,000," would have been an 
enforceable offer had the plaintiff called the television show to 
claim the reward while the tax protestor was appearing. See id. 
at 466-67. The court noted that, like Carbolic Smoke Ball, the 
case "concerns a special type of offer: an offer for a reward." 
Id. at 465. James v. Turilli, 473 S.W.2d 757 (Mo. Ct. App. 1971), 
arose from a boast by defendant that the "notorious Missouri 
desperado" Jesse James had not been killed  [*32]   in 1882, as 
portrayed in song and legend, but had lived under the alias "J. 
Frank Dalton" at the "Jesse James Museum" operated by none other 
than defendant. Defendant offered $10,000 "to anyone who could 
prove me wrong." See id. at 758-59. The widow of the outlaw's son 
demonstrated, at trial, that the outlaw had in fact been killed 
in 1882. On appeal, the court held that defendant should be 
liable to pay the amount offered. See id. at 762; see also Mears 
v. Nationwide Mutual Ins. Co., 91 F.3d 1118, 1122-23 (8th Cir. 
1996) (plaintiff entitled to cost of two Mercedes as reward for 
coining slogan for insurance company).  

   In the present case, the Harrier Jet commercial did not direct 
that anyone who appeared at Pepsi headquarters with 7,000,000 
Pepsi Points on the Fourth of July would receive a Harrier Jet. 
Instead, the commercial urged consumers to accumulate Pepsi 
Points and to refer to the Catalog to determine how they could 
redeem their Pepsi Points. The commercial sought a reciprocal 
promise, expressed through acceptance of, and compliance with, 
the terms of the Order Form. As noted previously, the Catalog 
contains no mention of  [*33]   the Harrier Jet. Plaintiff states 
that he "noted that the Harrier Jet was not among the items 
described in the catalog, but this did not affect [his] 
understanding of the offer." (Pl. Mem. at 4.) It should have. n10
 
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   n10 In his affidavit, plaintiff places great emphasis on a 
press release written by defendant, which characterizes the 
Harrier Jet as "the ultimate Pepsi Stuff award." (See Leonard 
Aff. P 13.) Plaintiff simply ignores the remainder of the 
release, which makes no mention of the Harrier Jet even as it 
sets forth in detail the number of points needed to redeem other 
merchandise.
 
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   Carbolic Smoke Ball itself draws a distinction between the 
offer of reward in that case, and typical advertisements, which 
are merely offers to negotiate. As Lord Justice Bowen explains:
 
It is an offer to become liable to any one who, before it is 
retracted, performs the condition . . . . It is not like cases in 
which you offer to negotiate, or you issue advertisements that 
you have got a stock of books to sell,   [*34]   or houses to 
let, in which case there is no offer to be bound by any contract. 
Such advertisements are offers to negotiate - offers to receive 
offers - offers to chaffer, as, I think, some learned judge in 
one of the cases has said.
 
Carbolic Smoke Ball, 1 Q.B. at 268; see also Lovett, 207 N.Y.S. 
at 756 (distinguishing advertisements, as invitation to offer, 
from offers of reward made in advertisements, such as Carbolic 
Smoke Ball). Because the alleged offer in this case was, at most, 
an advertisement to receive offers rather than an offer of 
reward, plaintiff cannot show that there was an offer made in the 
circumstances of this case.
 
C. An Objective, Reasonable Person Would Not Have Considered the 
Commercial an Offer  

   Plaintiff's understanding of the commercial as an offer must 
also be rejected because the Court finds that no objective person 
could reasonably have concluded that the commercial actually 
offered consumers a Harrier Jet.  

   1. Objective Reasonable Person Standard  

   In evaluating the commercial, the Court must not consider 
defendant's subjective intent in making the commercial, or 
plaintiff's subjective view of what  [*35]   the commercial 
offered, but what an objective, reasonable person would have 
understood the commercial to convey. See Kay-R Elec. Corp. v. 
Stone & Weber Constr. Co., 23 F.3d 55, 57 (2d Cir. 1994) ("We are 
not concerned with what was going through the heads of the 
parties at the time [of the alleged contract]. Rather, we are 
talking about the objective principles of contract law."); 
Mesaros, 845 F.2d at 1581 ("A basic rule of contracts holds that 
whether an offer has been made depends on the objective 
reasonableness of the alleged offeree's belief that the 
advertisement or solicitation was intended as an offer."); 
Farnsworth, supra, @ 3.10, at 237; Williston, supra, @ 4:7 at 
296-97.  

   If it is clear that an offer was not serious, then no offer 
has been made:
 
What kind of act creates a power of acceptance and is therefore 
an offer? It must be an expression of will or intention. It must 
be an act that leads the offeree reasonably to conclude that a 
power to create a contract is conferred. This applies to the 
content of the power as well as to the fact of its existence. It 
is on this ground that we must exclude invitations to deal [*36]   
or acts of mere preliminary negotiation, and acts evidently done 
in jest or without intent to create legal relations.
 
Corbin on Contracts, @ 1.11 at 30 (emphasis added). An obvious 
joke, of course, would not give rise to a contract. See, e.g., 
Graves v. Northern N.Y. Pub. Co., 260 A.D. 900, 22 N.Y.S.2d 537 
(App. Div. 4th Dept. 1940) (dismissing claim to offer of $1000, 
which appeared in the "joke column" of the newspaper, to any 
person who could provide a commonly available phone number). On 
the other hand, if there is no indication that the offer is 
"evidently in jest," and that an objective, reasonable person 
would find that the offer was serious, then there may be a valid 
offer. See Barnes, 549 P.2d at 1155 ("If the jest is not apparent 
and a reasonable hearer would believe that an offer was being 
made, then the speaker risks the formation of a contract which 
was not intended."); see also Lucy v. Zehmer, 196 Va. 493, 84 
S.E.2d 516, 518, 520 (Va. 1954) (ordering specific performance of 
a contract to purchase a farm despite defendant's protestation 
that the transaction was done in jest as "'just a bunch of two 
doggoned  [*37]   drunks bluffing'").  

   2. Necessity of a Jury Determination  

   Plaintiff also contends that summary judgment is improper 
because the question of whether the commercial conveyed a sincere 
offer can be answered only by a jury. Relying on dictum from 
Gallagher v. Delaney, 139 F.3d 338 (2d Cir. 1998), plaintiff 
argues that a federal judge comes from a "narrow segment of the 
enormously broad American socio-economic spectrum," id. at 342, 
and, thus, that the question whether the commercial constituted a 
serious offer must be decided by a jury composed of, inter alia, 
members of the "Pepsi Generation," who are, as plaintiff puts it, 
"young, open to adventure, willing to do the unconventional." 
(See Leonard Aff. P 2.) Plaintiff essentially argues that a 
federal judge would view his claim differently than fellow 
members of the "Pepsi Generation."  

   Plaintiff's argument that his claim must be put to a jury is 
without merit. Gallagher involved a claim of sexual harassment in 
which the defendant allegedly invited plaintiff to sit on his 
lap, gave her inappropriate Valentine's Day gifts, told her that 
"she brought out feelings that he had not had since [*38]   he 
was sixteen," and "invited her to help him feed the ducks in the 
pond, since he was 'a bachelor for the evening.'" Gallagher, 139 
F.3d at 344. The court concluded that a jury determination was 
particularly appropriate because a federal judge lacked "the 
current real-life experience required in interpreting subtle 
sexual dynamics of the workplace based on nuances, subtle 
perceptions, and implicit communications." Id. at 342. This case, 
in contrast, presents a question of whether there was an offer to 
enter into a contract, requiring the Court to determine how a 
reasonable, objective person would have understood defendant's 
commercial. Such an inquiry is commonly performed by courts on a 
motion for summary judgment. See Krumme, 143 F.3d at 83; Bourque, 
42 F.3d at 708; Wards Co., 761 F.2d at 120.  

   3. Whether the Commercial Was "Evidently Done In Jest"  

   Plaintiff's insistence that the commercial appears to be a 
serious offer requires the Court to explain why the commercial is 
funny. Explaining why a joke is funny is a daunting task; as the 
essayist E.B. White has remarked, "Humor can be dissected,   
[*39]   as a frog can, but the thing dies in the process . . . ." 
n11 The commercial is the embodiment of what defendant 
appropriately characterizes as "zany humor." (Def. Mem. at 18.)
 
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   n11 Quoted in Gerald R. Ford, Humor and the Presidency 23 
(1987).
 
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   First, the commercial suggests, as commercials often do, that 
use of the advertised product will transform what, for most 
youth, can be a fairly routine and ordinary experience. The 
military tattoo and stirring martial music, as well as the use of 
subtitles in a Courier font that scroll terse messages across the 
screen, such as "MONDAY 7:58 AM," evoke military and espionage 
thrillers. The implication of the commercial is that Pepsi Stuff 
merchandise will inject drama and moment into hitherto 
unexceptional lives. The commercial in this case thus makes the 
exaggerated claims similar to those of many television 
advertisements: that by consuming the featured clothing, car, 
beer, or potato chips, one will become attractive, stylish, 
desirable, and admired by all. A reasonable  [*40]   viewer would 
understand such advertisements as mere puffery, not as statements 
of fact, see, e.g., Hubbard v. General Motors Corp., 1996 U.S. 
Dist. LEXIS 6974, 95 Civ. 4362 (AGS), 1996 WL 274018, at *6 
(S.D.N.Y. May 22, 1996) (advertisement describing automobile as 
"Like a Rock," was mere puffery, not a warranty of quality); 
Lovett, 207 N.Y.S. at 756; and refrain from interpreting the 
promises of the commercial as being literally true. 

   Second, the callow youth featured in the commercial is a 
highly improbable pilot, one who could barely be trusted with the 
keys to his parents' car, much less the prize aircraft of the 
United States Marine Corps. Rather than checking the fuel gauges 
on his aircraft, the teenager spends his precious preflight 
minutes preening. The youth's concern for his coiffure appears to 
extend to his flying without a helmet. Finally, the teenager's 
comment that flying a Harrier Jet to school "sure beats the bus" 
evinces an improbably insouciant attitude toward the relative 
difficulty and danger of piloting a fighter plane in a 
residential area, as opposed to taking public transportation. n12
 
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   n12 In this respect, the teenager of the advertisement 
contrasts with the distinguished figures who testified to the 
effectiveness of the Carbolic Smoke Ball, including the Duchess 
of Sutherland; the Earls of Wharncliffe, Westmoreland, Cadogan, 
and Leitrim; the Countesses Dudley, Pembroke, and Aberdeen; the 
Marchionesses of Bath and Conyngham; Sir Henry Acland, the 
physician to the Prince of Wales; and Sir James Paget, sergeant 
surgeon to Queen Victoria. See Simpson, supra, at 265.
 
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 [*41]    

   Third, the notion of traveling to school in a Harrier Jet is 
an exaggerated adolescent fantasy. In this commercial, the 
fantasy is underscored by how the teenager's schoolmates gape in 
admiration, ignoring their physics lesson. The force of the wind 
generated by the Harrier Jet blows off one teacher's clothes, 
literally defrocking an authority figure. As if to emphasize the 
fantastic quality of having a Harrier Jet arrive at school, the 
Jet lands next to a plebeian bike rack. This fantasy is, of 
course, extremely unrealistic. No school would provide landing 
space for a student's fighter jet, or condone the disruption the 
jet's use would cause.  

   Fourth, the primary mission of a Harrier Jet, according to the 
United States Marine Corps, is to "attack and destroy surface 
targets under day and night visual conditions." United States 
Marine Corps, Factfile: AV-8B Harrier II (last modified Dec. 5, 
1995) . Manufactured by 
McDonnell Douglas, the Harrier Jet played a significant role in 
the air offensive of Operation Desert Storm in 1991. See id. The 
jet is designed to carry a considerable armament load, including 
Sidewinder and Maverick missiles. [*42]   See id. As one news 
report has noted, "Fully loaded, the Harrier can float like a 
butterfly and sting like a bee -- albeit a roaring 14-ton 
butterfly and a bee with 9,200 pounds of bombs and missiles." 
Jerry Allegood, Marines Rely on Harrier Jet, Despite Critics, 
News & Observer (Raleigh), Nov. 4, 1990, at C1. In light of the 
Harrier Jet's well-documented function in attacking and 
destroying surface and air targets, armed reconnaissance and air 
interdiction, and offensive and defensive anti-aircraft warfare, 
depiction of such a jet as a way to get to school in the morning 
is clearly not serious even if, as plaintiff contends, the jet is 
capable of being acquired "in a form that eliminates [its] 
potential for military use." (See Leonard Aff. P 20.)  

   Fifth, the number of Pepsi Points the commercial mentions as 
required to "purchase" the jet is 7,000,000. To amass that number 
of points, one would have to drink 7,000,000 Pepsis (or roughly 
190 Pepsis a day for the next hundred years -- an unlikely 
possibility), or one would have to purchase approximately 
$700,000 worth of Pepsi Points. The cost of a Harrier Jet is 
roughly $23 million dollars, a fact of which plaintiff was  [*43]   
aware when he set out to gather the amount he believed necessary 
to accept the alleged offer. (See Affidavit of Michael E. McCabe, 
96 Civ. 5320, Aug. 14, 1997, Exh. 6 (Leonard Business Plan).) 
Even if an objective, reasonable person were not aware of this 
fact, he would conclude that purchasing a fighter plane for 
$700,000 is a deal too good to be true. n13
 
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   n13 In contrast, the advertisers of the Carbolic Smoke Ball 
emphasized their earnestness, stating in the advertisement that 
"L 1,000 is deposited with the Alliance Bank, shewing our 
sincerity in the matter." Carbolic Smoke Ball, 1 Q.B. at 257. 
Similarly, in Barnes, the defendant's "subsequent statements, 
conduct, and the circumstances show an intent to lead any hearer 
to believe the statements were made seriously." Barnes, 549 P.2d 
at 1155. The offer in Barnes, moreover, was made in the serious 
forum of hearings before a state commission; not, as defendant 
states, at a "gambling convention." Compare Barnes, 549 P.2d at 
1154, with Def. Reply Mem. at 6.
 
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 [*44]    

   Plaintiff argues that a reasonable, objective person would 
have understood the commercial to make a serious offer of a 
Harrier Jet because there was "absolutely no distinction in the 
manner" (Pl. Mem. at 13,) in which the items in the commercial 
were presented. Plaintiff also relies upon a press release 
highlighting the promotional campaign, issued by defendant, in 
which "no mention is made by [defendant] of humor, or anything of 
the sort." (Id. at 5.) These arguments suggest merely that the 
humor of the promotional campaign was tongue in cheek. Humor is 
not limited to what Justice Cardozo called "the rough and 
boisterous joke . . . [that] evokes its own guffaws." Murphy v. 
Steeplechase Amusement Co., 250 N.Y. 479, 483, 166 N.E. 173, 174 
(1929). In light of the obvious absurdity of the commercial, the 
Court rejects plaintiff's argument that the commercial was not 
clearly in jest.  

   4. Plaintiff's Demands for Additional Discovery  

   In his Memorandum of Law, and in letters to the Court, 
plaintiff argues that additional discovery is necessary on the 
issues of whether and how defendant reacted to plaintiff's 
"acceptance" of their "offer"; how defendant and its [*45]   
employees understood the commercial would be viewed, based on 
test-marketing the commercial or on their own opinions; and how 
other individuals actually responded to the commercial when it 
was aired. (See Pl. Mem. at 1-2; Letter of David E. Nachman to 
the Hon. Kimba M. Wood, Apr. 5, 1999.)  

   Plaintiff argues that additional discovery is necessary as to 
how defendant reacted to his "acceptance," suggesting that it is 
significant that defendant twice changed the commercial, the 
first time to increase the number of Pepsi Points required to 
purchase a Harrier Jet to 700,000,000, and then again to amend 
the commercial to state the 700,000,000 amount and add "(Just 
Kidding)." (See Pl. Stat. Exh C (700 Million), and Exh. D (700 
Million -- Just Kidding).) Plaintiff concludes that, "Obviously, 
if PepsiCo truly believed that no one could take seriously the 
offer contained in the original ad that I saw, this change would 
have been totally unnecessary and superfluous." (Leonard Aff. P 
14.) The record does not suggest that the change in the amount of 
points is probative of the seriousness of the offer. The increase 
in the number of points needed to acquire a Harrier Jet may have 
been prompted  [*46]   less by the fear that reasonable people 
would demand Harrier Jets and more by the concern that 
unreasonable people would threaten frivolous litigation. Further 
discovery is unnecessary on the question of when and how the 
commercials changed because the question before the Court is 
whether the commercial that plaintiff saw and relied upon was an 
offer, not that any other commercial constituted an offer.  

   Plaintiff's demands for discovery relating to how defendant 
itself understood the offer are also unavailing. Such discovery 
would serve only to cast light on defendant's subjective intent 
in making the alleged offer, which is irrelevant to the question 
of whether an objective, reasonable person would have understood 
the commercial to be an offer. See Kay-R Elec. Corp., 23 F.3d at 
57 ("We are not concerned with what was going through the heads 
of the parties at the time [of the alleged contract]."); Mesaros, 
845 F.2d at 1581; Corbin on Contracts, @ 1.11 at 30. Indeed, 
plaintiff repeatedly argues that defendant's subjective intent is 
irrelevant. (See Pl. Mem. at 5, 8, 13.)  

   Finally, plaintiff's assertion that he should be afforded an 
opportunity [*47]   to determine whether other individuals also 
tried to accumulate enough Pepsi Points to "purchase" a Harrier 
Jet is unavailing. The possibility that there were other people 
who interpreted the commercial as an "offer" of a Harrier Jet 
does not render that belief any more or less reasonable. The 
alleged offer must be evaluated on its own terms. Having made the 
evaluation, the Court concludes that summary judgment is 
appropriate on the ground that no reasonable, objective person 
would have understood the commercial to be an offer. n14
 
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   n14 Even if plaintiff were allowed discovery on all of these 
issues, such discovery would be relevant only to the second basis 
for the Court's opinion, that no reasonable person would have 
understood the commercial to be an offer. That discovery would 
not change the basic principle that an advertisement is not an 
offer, as set forth in Section II.B of this Order and Opinion, 
supra; nor would it affect the conclusion that the alleged offer 
failed to comply with the Statute of Frauds, as set forth in 
Section II.D, infra.
 
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 [*48]   
 
D. The Alleged Contract Does Not Satisfy the Statute of Frauds  

   The absence of any writing setting forth the alleged contract 
in this case provides an entirely separate reason for granting 
summary judgment. Under the New York n15 Statute of Frauds,
 
a contract for the sale of goods for the price of $500 or more is 
not enforceable by way of action or defense unless there is some 
writing sufficient to indicate that a contract for sale has been 
made between the parties and signed by the party against whom 
enforcement is sought or by his authorized agent or broker.
 
N.Y.U.C.C. @ 2-201(1); see also, e.g., AFP Imaging Corp. v. 
Philips Medizin Systeme, 1994 U.S. Dist. LEXIS 16504, 92 Civ. 
6211 (LMM), 1994 WL 652510, at *4 (S.D.N.Y. Nov. 17, 1994)). 
Without such a writing, plaintiff's claim must fail as a matter 
of law. See Hilord Chem. Corp. v. Ricoh Elecs., Inc., 875 F.2d 
32, 36-37 (2d Cir. 1989) ("The adequacy of a writing for Statute 
of Frauds purposes 'must be determined from the documents 
themselves, as a matter of law.'") (quoting Bazak Int'l. Corp. v. 
Mast Indus., Inc., 73 N.Y.2d 113, 118, 538 N.Y.S.2d 503, 535 
N.E.2d 633 (1989)).
 
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   n15 Having determined that defendant's advertisement was not 
an offer, the last act necessary to complete the contract would 
be defendant's acceptance in New York of plaintiff's Order Form. 
Thus the Court must apply New York law on the statute of frauds 
issue. See supra Section II.A.2.
 
- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - 
 [*49]    

   There is simply no writing between the parties that evidences 
any transaction. Plaintiff argues that the commercial, 
plaintiff's completed Order Form, and perhaps other agreements 
signed by defendant which plaintiff has not yet seen, should 
suffice for Statute of Frauds purposes, either singly or taken 
together. (See Pl. Mem. at 18-19.) For the latter claim, 
plaintiff relies on Crabtree v. Elizabeth Arden Sales Corp., 305 
N.Y. 48, 110 N.E.2d 551 (N.Y. 1953). Crabtree held that a 
combination of signed and unsigned writings would satisfy the 
Statute of Frauds, "provided that they clearly refer to the same 
subject matter or transaction." Id. at 55. Yet the Second Circuit 
emphasized in Horn & Hardart Co. v. Pillsbury Co., 888 F.2d 8 (2d 
Cir. 1989), that this rule "contains two strict threshold 
requirements." Id. at 11. First, the signed writing relied upon 
must by itself establish "'a contractual relationship between the 
parties.'" Id. (quoting Crabtree, 305 N.Y. at 56); see also 
O'Keeffe v. Bry, 456 F. Supp. 822, 829 (S.D.N.Y. 1978) ("To the 
extent that Crabtree permits  [*50]   the use of a 'confluence of 
memoranda,' the minimum condition for such use is the existence 
of one [signed] document establishing the basic, underlying 
contractual commitment."). The second threshold requirement is 
that the unsigned writing must "'on its face refer to the same 
transaction as that set forth in the one that was signed.'" Horn 
& Hardart, 888 F.2d at 11 (quoting Crabtree, 305 N.Y. at 56); see 
also Bruce Realty Co. of Florida v. Berger, 327 F. Supp. 507, 510 
(S.D.N.Y. 1971).  

   None of the material relied upon by plaintiff meets either 
threshold requirement. The commercial is not a writing; 
plaintiff's completed order form does not bear the signature of 
defendant, or an agent thereof; and to the extent that plaintiff 
seeks discovery of any contracts between defendant and its 
advertisers, such discovery would be unavailing: plaintiff is not 
a party to, or a beneficiary of, any such contracts. Because the 
alleged contract does not meet the requirements of the Statute of 
Frauds, plaintiff has no claim for breach of contract or specific 
performance.
 
E. Plaintiff's Fraud Claim  

   In addition to moving for summary judgment  [*51]   on 
plaintiff's claim for breach of contract, defendant has also 
moved for summary judgment on plaintiff's fraud claim. The 
elements of a cause of action for fraud are "'representation of a 
material existing fact, falsity, scienter, deception and 
injury.'" New York Univ. v. Continental Ins. Co., 87 N.Y.2d 308, 
639 N.Y.S.2d 283, 662 N.E.2d 763 (1995) (quoting Channel Master 
Corp. v. Aluminium Ltd. Sales, Inc., 4 N.Y.2d 403, 407, 176 
N.Y.S.2d 259, 262, 151 N.E.2d 833 (1958)).  

   To properly state a claim for fraud, "plaintiff must allege a 
misrepresentation or material omission by defendant, on which it 
relied, that induced plaintiff" to perform an act. See NYU, 639 
N.Y.S.2d at 289. "General allegations that defendant entered into 
a contract while lacking the intent to perform it are 
insufficient to support the claim." See id. (citing Rocanova v. 
Equitable Life Assur. Soc'y, 83 N.Y.2d 603, 612 N.Y.S.2d 339, 634 
N.E.2d 940 (1994)); see also Grappo v. Alitalia Linee Aeree 
Italiane, S.P.A., 56 F.3d 427, 434 (2d Cir. 1995) ("A cause of 
action does not generally lie where the plaintiff alleges only 
that the  [*52]   defendant entered into a contract with no 
intention of performing it"). Instead, the plaintiff must show 
the misrepresentation was collateral, or served as an inducement, 
to a separate agreement between the parties. See 
Bridgestone/Firestone v. Recovery Credit, 98 F.3d 13, 20 (2d Cir. 
1996) (allowing a fraud claim where plaintiff "'demonstrate[s] a 
fraudulent misrepresentation collateral or extraneous to the 
contract'") (quoting Deerfield Communications Corp. v. 
Chesebrough-Ponds, Inc., 68 N.Y.2d 954, 510 N.Y.S.2d 88, 89, 502 
N.E.2d 1003 (1986)).  

   For example, in Stewart v. Jackson & Nash, 976 F.2d 86 (2d 
Cir. 1992), the Second Circuit ruled that plaintiff had properly 
stated a claim for fraud. In the course of plaintiff's 
negotiations for employment with defendant, a law firm, defendant 
represented to plaintiff not only that plaintiff would be hired 
(which she was), but also that the firm had secured a large 
environmental law client, that it was in the process of 
establishing an environmental law department, and that plaintiff 
would head the environmental law department. See id. at 89-90. 
The Second Circuit concluded  [*53]   that these 
misrepresentations gave rise to a fraud claim, because they 
consisted of misrepresentations of present fact, rather than 
future promises.  

   Plaintiff in this case does not allege that he was induced to 
enter into a contract by some collateral misrepresentation, but 
rather that defendant never had any intention of making good on 
its "offer" of a Harrier Jet. (See Pl. Mem. at 23.) Because this 
claim "alleges only that the defendant entered into a contract 
with no intention of performing it," Grappo, 56 F.3d at 434, 
judgment on this claim should enter for defendant.  

   III. Conclusion  

   In sum, there are three reasons why plaintiff's demand cannot 
prevail as a matter of law. First, the commercial was merely an 
advertisement, not a unilateral offer. Second, the tongue-in-
cheek attitude of the commercial would not cause a reasonable 
person to conclude that a soft drink company would be giving away 
fighter planes as part of a promotion. Third, there is no writing 
between the parties sufficient to satisfy the Statute of Frauds.  

   For the reasons stated above, the Court grants defendant's 
motion for summary judgment. The Clerk of Court is instructed to 
close  [*54]   these cases. Any pending motions are moot.  

   SO ORDERED.
 
Dated: New York, New York 

   August 4, 1999  

   Kimba M. Wood  

   United States District Judge