both an advantage in additional sales in reaction to the advertisement and a "distinct inconvenience" that people go to when using a smoke ball. Lord Justice Bowen Bowen's opinion was more tightly structured in style and is frequently cited. Five main steps in his reasoning can be identified. First, he says that the contract was not too vague to be enforced, because it could be interpreted according to what ordinary people would understand by it. He differed slightly from Lindley on what time period one could contract flu and still have a claim (Lindley said a "reasonable time" after use, while Bowen said "while the smoke ball is used"), but this was not a crucial point, because the fact was that Carlill got flu while using the smoke ball. Second, like Lindley, Bowen says that the advert was not mere puff because £1000 was deposited in the bank to pay rewards. Third, he said that although an offer was made to the whole world, the contract was not with the whole world. Therefore, it was not an absurd basis for a contract, because only the people who used it would bind the company. Fourth, he says that communication is not necessary to accept the terms of an offer; conduct is and should be sufficient. Fifth, good consideration was clearly given by Carlill because she went to the "inconvenience" of using it, and the company got the benefit of extra sales. Lord Justice Smith A L Smith's judgment was more general and concurred with both Lindley and Bowen's decisions. Significance Carlill is significant for two areas of law: the law of contract, and the doctrine of puffery. Both areas have impacted advertising, and the problem of medical quackery. Law of contract Carlill is frequently cited as a leading case in the common law of contract, particularly where unilateral contracts are concerned. It provides an excellent study of the basic principles of contract and how they relate to everyday life. The case remains good law. It still binds the lower courts of England and Wales and is cited by judges with approval. However, in addition to the contractual remedy afforded to users, the same facts would give rise to a number of additional statutory remedies and punishments were an individual to place an advert in the same terms today. Firstly, misleading advertising is a criminal offence. Under the Consumer Protection from Unfair