Bo Jackson is a multi-sport athlete. One day, Itchitin, a company that makes a cream for athlete's foot, puts out an advertisement that proclaims "Bo KNOWS foot fungus and Bo LOVES Itchitin." In fact, Bo does use Itchitin when he gets athlete's foot. However, Bo did not know of or consent to the ad. If Bo wants to sue Itchitin, What would his best cause of action be ________.