The Seventh Circuit recently held that a complaining party is not required to establish reliance, either actual or reasonable, in order to state a claim under the Illinois Consumer Fraud Act. The Seventh Circuit opinion, authored by Judge Williams, rejected several contrary decisions of the Illinois Appellate Court in light of prior Illinois Supreme Court rulings. Cozzi Iron & Metal, Inc. v. U.S. Office Equipment, Inc., 250 F.3d 570 (7th Cir. 2001).
