Laff v. Best Buy Stores, L.P., 2010 WL 2220581, at *3 (N.D. Ill. June 3, 2010) (dismissing count alleging breach of good faith and fair dealing); Zeidler v. A & W Restaurants, Inc., 301 F.3d 572, 575 (7th Cir. 2002) (noting that the district court correctly dismissed the plaintiff's claim that the defendant breached an independent covenant of good faith and fair dealing because that covenant is "not a source of contractual duties or liability under Illinois law."); see also Echo, Inc. v. Timberland Machines & Irrigation, Inc., 2009 WL 562539, at *3 (N.D. Ill. March 5, 2009) (dismissing breach of good faith and fair dealing claim because "it is not an independent cause of action under Illinois law;" and noting that while "[i]n Illinois, contracting parties are held to an implied duty of good faith and fair dealing," that obligation "is mainly used as a construction aid to determine the intent of the parties in case of conflicting terms") (citing cases). However, in his response brief (at 17), Plaintiff discusses his ninth cause of action in terms of a "breach of the contracts granting Baxi shares in EK."