In Ananda Church of Self-Realization v. Massachusetts Bay Ins. Co. (2002) 95 Cal. App. 4th 1273, an insurance policy provision insuring against property damage, defined as injury to or loss of tangible property, did not cover the taking of documents placed in an outdoor trash barrel. The court said that "documents which have been placed in an outdoor trash barrel no longer retain their character as the personal property of the one who has discarded it. By placing them into the garbage, the owner renounces the key incidents of ownership--title, possession, and the right to control." (Ananda, supra, 95 Cal. App. 4th at p. 1282.) The court concluded that a claim for conversion or other interference with personal property rights may not be based on the taking of personalty discarded as waste, because waste is considered to be abandoned property. (Id. at pp. 1281-1282.)