Z’s IT Consulting Services, Inc. v. Hunt Law Group, LLC

Plaintiffs filed a lawsuit for breach of contract against a law firm that the plaintiffs had provided IT consulting services to. The law firm defendant then filed a counterclaim for conversion alleging that plaintiffs withheld passwords and access codes that would allow the law firm to access its IT systems. The trial court dismissed the counterclaim, finding that the converted assets were intangible and, as a result, could not support a civil conversion action in Illinois and defendant appealed. The appellate court affirmed, finding that the assets in question were not tangible and declining to expand Illinois law to allow for conversion claims of non-tangible assets. (ANDERSON, concurring and specially concurring and HOLDRIDGE, dissenting)