California, United States of America
The following excerpt is from Wells Fargo Bank, N.A. v. Jackson Jenkins Renstrom LLP, A138307 (Cal. App. 2015):
Cases holding that a conversion claim fails because the simple failure to pay money owed does not constitute conversion (see, e.g., Kim v. Westmoore Partners, Inc. (2011) 201 Cal.App.4th 267, 284), are not applicable here, because in those cases, there was no taking of intangible property.
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