What is the test for waiving a claim for fraud or fraudulent misrepresentation?

MultiRegion, United States of America

The following excerpt is from Cortes v. 21ST Century Fox Am., Inc., No. 18-0414-cv (2nd Cir. 2018):

claim for fraud or fraudulent misrepresentation. Accordingly, he has waived any appeal as to these claims. See, e.g., Norton v. Sam's Club, 145 F.3d 114, 117 (2d Cir. 1998) ("Issues not sufficiently argued in the briefs are considered waived and normally will not be addressed on appeal.")

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