Ownership Interest in LLC is Intangible Property Not Subject to Conversion

On March 23, 2017, the First Department issued a decision in Saleeby v. Remco Maintenance, LLC, 2017 NY Slip Op. 02140, affirming the dismissal of a conversion claim based on an ownership interest in an LLC because a "7.5% 'common interest' ownership share in a limited liability company was a type of intangible property that could not be the subject of a conversion claim."