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124671 -

: To prevent defendants from constantly "picking off" plaintiffs, the court noted that if a motion for class certification is already pending, a tender cannot moot the case. 4. Key Takeaways and Legacy

: While the plaintiffs lost this specific battle, the case reinforced the strict requirements for landlords under the Security Deposit Interest Act. Other potential topics associated with "124671":

: The U.S. Supreme Court had previously ruled in Campbell-Ewald Co. v. Gomez that an unaccepted settlement offer does not make a case moot in federal court. 3. The Supreme Court's Decision 124671

: SVM Management argued that because they offered the plaintiffs everything they personally asked for, there was no longer a "controversy," making the case moot .

In this case, plaintiffs Chandra Joiner and William Blackmond sued their landlord, SVM Management, for failing to pay interest on their security deposits as required by the Illinois Security Deposit Interest Act . : To prevent defendants from constantly "picking off"

: Reaffirming its own precedent (the Barber rule), the court held that an effective tender made before a class-certification motion is filed satisfies the individual claim and moots the interest in the litigation.

: The court explicitly declined to follow the federal Campbell-Ewald standard, asserting its role as the final arbiter of Illinois state law. Other potential topics associated with "124671": : The U

: For plaintiffs in Illinois, filing a motion for class certification simultaneously with the complaint is now a common strategy to prevent a "pick-off" tender.