RATHER than buying goods outright, retailers often find it convenient to receive goods under a “sale or return” arrangement. These agreements are not contracts of sale, but rather bailment arrangements that give the bailee the right either to buy or to reject the goods. A sale or return contract may require that the right to reject can be exercised only by the bailee physically returning any unwanted goods; however, in the absence of an express stipulation to this effect, these contracts are generally construed to require merely that the bailee give notice of rejection and make the goods available for collection by the bailor. The question then arises: what form must this notice take, and at what stage must the goods be made available for collection? These matters were considered by the Court of Appeal in Atari Corporation (U.K.) Ltd. v. Electronics Boutique Stores (U.K.) Ltd. [1998] 2 W.L.R. 66.