In the Case in the Text,Pena V

In the case in the text,Pena v.Fox,the court held that the release delivered constituted a(n) :

A) counteroffer because the release did not mirror Pena's offer.
B) counteroffer because the release contained a different settlement amount.
C) acceptance because the additional terms were not material.
D) acceptance because the release mirrored Pena's offer.