Integrated Direct Marketing, LLC, Petitioner v. Drew May and Merkle, Inc., Respondents

Summary

The court answered the certified question affirmatively, holding that intangible property such as electronically stored data may be converted under Arkansas law even when it is not a trade secret. Conversion requires a distinct act of dominion that denies or is inconsistent with the owner's rights, but it does not require complete deprivation of the property.