of obligation.” Filak v. George, 267 Va. 612, 619, 594 S.E.2d 610 (2004). A legally enforceable obligation, or contract, requires that there be “acceptance of an offer ... as well as valuable consideration.” Montagna v. Holiday Inns, Inc., 221 Va. 336, 346, 269 S.E.2d 838 (1980) (citation omitted). A request for bids is not an offer, rather the bid itself is an offer, which creates no right until it is accepted by the offeree. Monk v. Va. Dep’t of Transp., 1994 WL 1031334, 34 Va. Cir. 374, 376 (Va. Cir. Ct.1994); 1 Richard A. Lord, Williston on Contracts § 4:10 (4th ed.1990). As to Count One of its Amended Complaint, Plaintiff fails to state a claim for breach of contract against Amtrak because it does not allege acceptance of an offer. See Montagna, 221 Va. at 346, 269 S.E.2d 838 (<HOLDING>). While Plaintiff claims it was the lowest
holding that an offer to donate cannot be an offer to sell holding that offer of atwill employment is valid consideration to support an arbitration agreement holding that a valid contract requires acceptance of an offer holding that performance may be valid acceptance holding that complete performance of contract constituted acceptance