Earley v. Texaco Refining and Marketing, Inc., CCH BFG 9491 (D. Ore. 10-16-89); No. 89-6367-E (D. Ore. 6-8-90) Slip Opinion; rev'd and remanded 951 F.2d 1059 (9th Cir. 12-31-91)

Injunction for franchisee reversed and remanded. Ten "sincere" customer complaints in 18 months was "numerous" enough to constitute bona fide customer complaints to provide grounds for nonrenewal. The trial court had found that of the twelve customer complaints franchisor relied upon, the court found only two were bona fide. Franchisee had resolved the others.