Afzal Lokhandwala owns and operates eight KFC franchises in Illinois. Each franchise operates under an identical franchise agreement.

Lokhandwala says he identified selling Halal chicken as a lucrative business opportunity as early as 2002, when he opened his first franchise. “Halal” refers to food prepared in accordance with Islamic laws and customs. When Lokhandwala discussed selling Halal chicken in 2002, KFC’s franchise director, Ken Taft, promised Lokhandwala that KFC would approve him selling Halal chicken. From 2003 through early 2017, all of the chicken-on-the-bone (as distinct from other chicken products, like chicken tenders) that Lokhandwala’s stores sold came from Halal-certified poultry processors that KFC approved. In late 2016 or early 2017, however, KFC changed course and demanded that Lokhandwala stop marketing his products as Halal. Lokhandwala says that this policy contradicts the representations that KFC made to him when he opened stores in 2010 and 2012 allowing him to continue advertising Halal products in his stores. When KFC ordered Lokhandwala to stop marketing his products as Halal, KFC also told Lokhandwala to remove signs from his stores that disclosed the Halal status, names, and addresses of Lokhandwala’s chicken processors and distributors. Lokhandwala believes that Illinois regulations require him to post such signs because he certified his franchises as Halal Registered Brokers with the Illinois Department of Agriculture in 2017.

Lokhandwala sued KFC, and KFC moved to dismiss the claim. How much control should a franchisor have over a franchisee’s advertising?

How did the court rule?