On December 19, 2024, Justice Ruchelsman of the Kings County Commercial Division issued a decision in Lingang Li v. Howe, 2024 NY Slip Op. 34490(U), holding that a claim based on an alleged oral agreement to sell shares of a company that only owned real property was barred by the statute of frauds, explaining:
It is well settled that a contract for the sale of any interest in land must be in writing to be enforceable. This includes any contract for the shares of stock in an entity whose: sole asset consists of ownership interests in land.
Therefore, the motion seeking to dismiss all the breach of contract causes of action is granted.
(Internal citations omitted).