LexisNexis (February 4, 2020, 11:23 AM EST) -- A company victimized by unauthorized ACH debit transactions received bad news from a court in Florida. In Industrial Park Dev. Corp. v. American Express Bank, 2013 U.S. Dist. Lexis 13929 (M.D. Fla. 2013), the company (i.e., the “receiver” of the ACH debits) sued the ODFl. The only claim made by the company was for conversion, and the court concluded that allocation of loss was governed exclusively by Article 4A of the UCC, which it felt displaced common-law claims such as conversion. For good measure, the Florida court also found that the complaint did not provide sufficient facts to support a conversion claim. In addition to the Florida case, we also analyze recent cases in this area from Pennsylvania and California....