Alvarez-Espina v. Gasolinas de Puerto Rico Corp., 2008 U.S. Dist. LEXIS 25762 (D.P.R. 3-28-08)

Summary judgment granted to franchisor on franchisee’s PMPA claim for improper franchise termination. Franchisee had failed to pay rent for more than a year, but argued that he paid the back rent in accordance with correspondence from franchisor, which gave him an opportunity to cure, and that franchisor had not given 90 days’ notice. Court held that franchisee did not cure his default as provided by franchisor’s correspondence and that less than 90 days’ notice for failure to pay was proper.