Tuesday, September 16, 2008
In a recent opinion (pdf), the United States District Court for the Western District of Virginia addressed a 21st century conversion claim: a former employee forwarded an allegedly proprietary email to his personal account, and then used the information to solicit people for a competitor. The court found that these allegations stated a cause of action for conversion, and denied the employee's motion to dismiss reasoning that the "conversion claim does not fail merely because the property at issue is an electronic version of the list rather than a hard copy." (Slip Op. at 20-21).
(Thanks to Meredith Miller (Touro) for the tip).