Our April 18, 2019, column addressed the Commercial Division’s assessments of the various elements of unjust enrichment claims. “Pleading and Proving Unjust Enrichment Claims,” N.Y.L.J. Apr. 18, 2019. Since then, one element, reliance or inducement, has taken center stage in more recent Commercial Division cases. While New York Court of Appeals precedent seemed to suggest that pleading a sufficient connection also required pleading reliance or inducement, at least one recent decision indicates that may be reading too much into that precedent. In this column, we examine the role of reliance or inducement when pleading a sufficiently close relationship in an unjust enrichment claim.

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