Quantum meruit literally means "'as much as he deserves.'" Rohter v. Passarella, 246 Ill. App. 3d 860, 866, 617 N.E.2d 46 (1993), quoting Black's Law Dictionary 649 (abr. 5th ed. 1983). "The common law adopted the term to describe a cause of action which seeks to recover the reasonable value of services which have been nongratuitously rendered, but where no contract exists to prescribe exactly how much the [plaintiff] should have been paid."

However, he did not file his complaint until May 2014, some 41 months later. Thus, we conclude that the trial court did not err in the way that it applied the "last rendition of services" test to appellant's claim for breach of an implied-in-fact contract against Gingold, and affirm the dismissal of this claim as time-barred. SeeDolan , 2016 WL 7235627, at *3–4 ; Rohter v. Passarella , 246 Ill.App.3d 860, 186 Ill.Dec. 807, 617 N.E.2d 46, 52 (1993) (statute of limitations began to run as soon as plaintiff could have invoiced defendants and then sought relief in court). Application of the "discovery rule," which appellant argues for in his brief, would not be appropriate, because nothing in appellant's complaint suggests that the alleged injury here was latent or that it required due diligence on appellant's part to discover it. Under the "discovery" rule, a "cause of action accrues ‘when the plaintiff[s] know [ ] or through the exercise of due diligence should have known of the injury.

See Koba, 194 Md.App. at 420; See also News World Communications, Inc. v. Thompsen, 878 A.2d 1218, 1225 (D.C.2003) (citing Zic v. Italian Gov't. Travel Office, 149 F.Supp.2d 473, 476 (N.D.Ill.2001) ("[T]he essence of a quantum merit claim...is not the plaintiff's expectancy of payment, but the unjust enrichment of the defendant and...the defendant was unjustly enriched when the services were rendered and when payment was refused."). We discussed Rohter v. Passarella, 246 Ill.App.3d 860 (1993), wherein an Illinois court rejected as untimely a tax accountant's quantum merit claims when he waited more than 5 years to file suit after rendering services. See generally Rohter, 246 Ill.App. at 861-70.

Rutledge v. Housing Auth. of E. St. Louis, 88 Ill. App.3d 1064, 44 Ill. Dec. 176, 411 N.E.2d 82, 85-86 (1980). Thus, the cause of action accrues upon presentment and subsequent rejection of a bill for services, or as soon as the services were rendered. Rohter v. Passarella, 246 Ill. App.3d 860, 186 Ill. Dec. 807, 617 N.E.2d 46, 52 (1993). The remaining question is when Mr. Zic would have been entitled to demand payment.

Rutledge v. Housing Auth. of E. St. Louis, 411 N.E.2d 82, 85-86 (Ill.App.Ct. 1980). Thus, the cause of action accrues upon presentment and subsequent rejection of a bill for services, or as soon as the services were rendered. Rohter v. Passarella, 617 N.E.2d 46, 52 (Ill.App.Ct. 1993). The remaining question is when Mr. Zic would have been entitled to demand payment.

Generally, a claim accrues when a party has a right to invoke the aid of the court to enforce its remedy. Berg Associates, Inc. v. Nelsen Steel Wire Co., 221 Ill. App.3d 526, 162 Ill.Dec. 779, 580 N.E.2d 1198 (1st Dist. 1991). Defendants argue that for purposes of the statute of limitations, when services are allegedly performed and no time period has been specified for payment, the law presumes that the services were to be paid for at the end of the year in which they were rendered. Schmidt v. Pfau, 114 Ill. 494, 2 N.E. 522 (1885); Rohter v. Passarella., 246 Ill. App.3d 860, 870, 186 Ill. Dec. 807, 617 N.E.2d 46 (1st Dist. 1993). Thus, defendants argue that any claim for services rendered by plaintiff prior to January 1, 1991, (i.e., for the years 1986 through 1990) is barred by the statute of limitations, plaintiff having filed his complaint in November 1996.

Hudgens Dep. at 150-51. While it is not clear the extent to which the Corporate Defendants benefited from ISC's work, Rohter v. Passarella, 246 Ill. App.3d 860, 186 Ill.Dec. 807, 811, 617 N.E.2d 46, 50 (1993) (measure of damages in quantum meruit is reasonable value of benefit received by defendant), there is sufficient evidence in the record from which a jury could conclude that the defendants did unjustly benefit from ISC's services. The defendants contend that ISC cannot recover any benefits it may have bestowed on them because the parties were still negotiating over whether to use ISC as a supplier and ISC did not expect to be directly reimbursed for its "preliminary services."

Courts of this state have held that a statute of limitation begins to run when the party to be barred has the right to invoke the aid of the court to enforce his remedy. Milnes v. Hunt, 311 Ill. App.3d 977, 980 (2000); Rohter v. Passarella, 246 Ill. App.3d 860, 869 (1993). Stated another way, a limitation period begins "when facts exist which authorize one party to maintain an action against another."

Put another way, "[t]he general principle is that a 'statute of limitations begins to run when the party to be barred has the right to invoke the aid of the court and to enforce his remedy.' " Rohter v. Passarella, 246 Ill. App. 3d 860, 869 (1993), quoting Berg & Associates v. Nelsen Steel & Wire Co., 221 Ill. App. 3d 526, 532 (1991). ¶ 19 The plaintiff's sole contention on appeal is that his claim in Count I did not accrue until February 2011, because the defendants' failure to convey title to Unit 1605 and P-13 did not constitute a breach of the Oral Agreement until that time.

¶ 20 Klein nonetheless argues that RTKL failed to prove the reasonable value of its services because the invoices did not state which employees or contractor completed what work and how many people were working on a given aspect of the project. Citing Rohter v. Passarella, 246 Ill. App. 3d 860, 868 (1993) (quoting In re Irving-Austin Building Corp., 100 F.2d 574, 578 (7th Cir. 1938)), Klein reasons that the reasonable value of services rendered is measured "not by the amount of time and energy expended by the laboring party but by the value of such services to the beneficiary." ¶ 21 RTKL responds that it had presented invoices setting forth both the hourly rates and number of hours expended that the circuit court found were reasonable, that Mendes testified regarding her personal responsibility for preparing the invoices for Klein's Chicago and Miami projects, which in accordance with standard custom and practice, were derived from a computerized timekeeping system that logged each employee who worked on either the Chicago or Miami project, and that Klein had presented no evidence to suggest otherwise, acknowledging at trial that he had no basis to dispute the accuracy of Mendes's testimony about the accuracy of RTKL's invoices. RTKL adds, and we agree, that Klein's reliance on Roht