attorneys’ fees can accrue after the filing of a suit, while punitive damages do not — is meaningful. Once post-filing of suit tender of compensatory damages is accomplished, attorneys’ fees can accrue continuously until the matter is fully resolved, thus presenting a cognizable harm sufficient to prevent a case from having been rendered moot by post-suit tender of compensatory damages, unlike punitive damages. See, e.g., Bates, 271 Ill.Dec. 402, 785 N.E.2d at 62 (“Defendant failed to tender the attorney fees recoverable under section 10a(c) of the Consumer Fraud Act, and thus, failed to tender the ‘full amount’ owed to plaintiff.”). Punitive damages, thus, should not be available as a matter of law as a result of the pre-tria 3d 1075, 248 Ill.Dec. 721, 734 N.E.2d 1012, 1015 (2000) (<HOLDING>); DeCoteau v. Nodak Mutual Insurance Company,
recognizing a narrow class of cases in which the termination of the class representatives claim for relief does not moot the claims of the class members holding that because the record in the case had not been developed sufficiently to determine whether a childs statement was admissible under the tender years exception a new trial was warranted holding that the dismissal of a class action suit after the representative plaintiffs claims became moot was proper noting that  because the class action was never properly certified nor the class properly identified by the district court the decision that the claims of the purported representative were moot dictated the dismissal of the uncertified class action as well quoting bd of school commrs v jacobs 420 us 128 130 95 sct 848 850 43 led2d 74 78 1975 per curiam holding that because no class was certified at the time tender rendered moot haymans claims dismissal of the entire suit was warranted holding that because no class was certified at the time the individual claims were dismissed the class action was properly dismissed