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Yakima Company (LC Applicant) sued Lincoln General Ins. Co. (Beneficiary) for conversion of the proceeds of a standby LC. The United States Court of Appeals, Ninth Circuit affirmed the district court's dismissal of the action because LC Applicant had neither title nor right to possession of the LC proceeds, a necessary element for conversion.

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This article represents the views of the author and not necessarily those of the ICC or any of the other partners in DC-PRO.