Narrative Opinion Summary
In a class action lawsuit, the Ninth Circuit affirmed the district court's summary judgment in favor of Google LLC, addressing claims for breach of contract and conversion. The plaintiff, representing himself and a class, contended that an email from Google constituted an offer for a lifetime of one terabyte of free Google Drive storage, based on his contributions to Google Maps and subsequent participation in the Local Guides Program. The case revolved around the interpretation of several documents, including the 'Photo Impact Email', the Enrollment Page, and the Program Rules. The district court found that these documents failed to establish a unilateral contract, as they did not clearly articulate the terms of the offer or the necessary acceptance criteria. Advertisements, while generally not considered offers, can be exceptions if they present clear terms; however, the court determined that Google's communications did not meet this standard. The conversion claim was dismissed as it was contingent upon the breach of contract claim. On appeal, the Ninth Circuit upheld the lower court's rulings, agreeing that there was no genuine issue of material fact regarding contract formation and affirming summary judgment in Google's favor on both claims.
Legal Issues Addressed
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Application: The court concluded that Google's email did not meet the criteria for an offer under California law, as it was too ambiguous to be considered a reward offer.
Reasoning: It noted that advertisements are not typically considered offers, but recognized an exception for reward offers if clear terms are provided.
Breach of Contract under California Contract Lawsubscribe to see similar legal issues
Application: The court determined that Google's email did not constitute a unilateral contract offering lifetime storage, as it lacked specificity in terms of acceptance and conditions for the offer.
Reasoning: The district court evaluated three documents—the Photo Impact Email, the Enrollment Page, and the Program Rules—and determined they did not represent a unilateral contract offering lifetime storage.
Conversion Claim Dependent on Contract Claimsubscribe to see similar legal issues
Application: The conversion claim was dismissed as it was dependent on the breach of contract claim, which failed to establish the existence of a contract.
Reasoning: Consequently, the court found no unilateral contract existed and granted summary judgment for Google on both the breach of contract and conversion claims, as the latter was dependent on the former.
Jurisdiction and Appealsubscribe to see similar legal issues
Application: The appellate court reviewed the summary judgment de novo under 28 U.S.C. 1291, affirming the lower court's decision.
Reasoning: The appellate court has jurisdiction under 28 U.S.C. 1291 and will review the summary judgment de novo.
Summary Judgment Standardssubscribe to see similar legal issues
Application: The Ninth Circuit upheld the district court's summary judgment as there were no genuine disputes of material fact regarding the existence of a contract.
Reasoning: The Ninth Circuit affirmed the district court's summary judgment in favor of Google LLC regarding breach of contract and conversion claims in a class action lawsuit.