Gottlieb v. Tropicana Casino

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Gottlieb v. Tropicana Casino
Court United States District Court for the Eastern District of Pennsylvania
Date decided 2000-7-5


The Tropicana Hotel and Casino in Atlantic City, New Jersey, offered a free Diamond membership program to patrons who provided their basic personal information.

Diamond members were issued identification card to swipe at casino machines. This allowed the casino to offer personal ads to the patrons.

Ms Gottlieb who lived in Pennsylvania became a Tropicana Diamond member to participate in the Funhouse Million Dollar Wheel promotion.

Ms Gottlieb claimed that the wheel landed on the $1 million prize; however, the game attendant immediately re-spun the wheel.

Procedural History

Gottlieb sued Tropicana (the casino) for contract breach in federal district court under diversity jurisdiction.

Tropicana moved for summary judgment because Gottlieb didn't provide consideration to spin the wheel.


Is a minimal detriment incurred for participation in a promotional contest sufficient consideration to form a contract?


Yes. A person who incurs minimal detriment to participate in a promotional contest provides sufficient consideration to form an enforceable contract.