On April 11, 2023, Justice Crane of the New York County Commercial Division issued a decision in Pragad v. Davis, 2023 NY Slip Op. 31209(U), dismissing a claim for conspiracy as duplicative of a claim for aiding and abetting, explaining:
However, the court grants Davis’s motion to dismiss the cause of action for conspiracy to convert. A claim for conspiracy is subject to dismissal where it is duplicative of an aiding and abetting cause of action. Here, the cause of action for conspiracy alleges substantially the same claim against Davis as the cause of action for aiding and abetting conversion, i.e., that Davis directed Choi to delete user accounts from the Workspace. As such, the court dismisses the conspiracy claim.
(Internal quotations omitted).