IL: Appellate Court Declines to Extend Conversion to Intangible Assets

Recently, an Illinois appellate court insisted on the traditional limitations of tangible property or the merger doctrine for the tort of conversion.  Z’s IT Consulting Servs., Inc. v. Hunt L. Grp., LLC, 2024 IL App (3d) 230333, ¶ 21, ___ Ill. Dec. ___, ___, ____ N.E.3d ___, ____ (2024) (declining to extend conversion to intangible assets;  “[Counterclaimant] fails to allege that plaintiffs converted a document in which intangible rights were merged or that plaintiffs prevented the exercise of [counterclaimant’s] intangible rights that are customarily merged into a document.”).