Laurens v. Volvo Cars of North America, LLC

WOOD, Chief Judge.

The idea of a theme and variations is a common one in music. It should be in law, too. Here we return to the familiar theme of a defense effort to pretermit a proposed class action by picking off the named plaintiffs claim. Several variations on that theme have been tried and have failed. See Campbell-Ewald Co. v. Gomez, — U.S. —, 136 S.Ct. 663, 193 L.Ed.2d 571 (2016) (Rule 68 offers of judgment); Fulton Dental, LLC v. Bisco, Inc., 860 F.3d 541 (7th Cir. 2017) (Rule 67 payments to court registry).

Undeterred, the defendant in the case now before us asserts that an unaccepted…