What damages are available to a franchisee under the California Franchise Relations Act (CFRA) for a wrongful termination or nonrenewal? In JRS Products, Inc. v. Matsushita Electric Corp. of America, 115 Cal. App. 4^th 168, 8 Cal. Rptr 3d 840 (Cal. App. 2004), modified on denial of reh’g, a California court of appeals clarified that a franchisee who alleges that it was terminated without good cause in violation of the CFRA is not limited to the repurchase of inventory as its exclusive remedy. However, the court determined that a termination without good cause sounds fundamentally in breach of contract and that a franchisee must pursue its action and its remedies under contract law, rather than tort law. The significance of this is that terminated franchisees are less likely to be able to recover punitive or exemplary damages.