In Prescott v. Jones (69 N.H. 305, 41 A. 352 (N.H. 1898)), the defendant had insured the plaintiff's building. At the end of the first year, the insurance company wrote Prescott and told him that they would automatically renew the policy for another year, "unless notified to the contrary." Prescott made no reply, the insurance company didn't renew the policy, and the building burned down a few months later. The Court found that there was no active acceptance on the part of Prescott, and there was no reliance because the letter was just an 'intent' to sell insurance, it was not a guarantee of insurance.