2. In ANHEUSER–BUSCH, INC. v. JOHN LABATT LTD., 89 F.3d 1339, 1349 (8th Cir.

1996), certiorari denied 519 U.S. 1109, 117 S.Ct. 944, 136 L.Ed. 2d 833 (1997), plaintiff failed to mention punitive damages in its pleadings or answers to interrogatories. Plaintiff did plead a valid claim for injurious falsehood under state law and requested instructions on punitive damages a week prior to the trial. Over defendant’s objection the matter was presented to the jury, which awarded punitive damages in the amount of $5 million. The trial court struck the punitive damage award on the ground that plaintiff had not given sufficient notice of its intent to seek punitive damages. The appellate court affirmed. It did not cite Federal Rules 8(a)(3), 9(g), or 54(c). Should it have been unnecessary for plaintiff to specify punitive damages in its demand for relief so long as the alleged facts would justify such an award?