Akky v. BP America, No. C 94-0080 SBA (N.D. Cal. 5-25-94) Slip Opinion; aff'd, 73 F.3d 974 (9th Cir. 1-17-96)

No cause of action because franchisor rescinded all prior notices of termination. Because threat of termination is speculative, it does not amount to a violation of the PMPA. "Constructive termination" not yet recognized by 9th Circuit.