In Allied Inv. Corp. v. Jasen, 354 Md. 547, 731 A.2d 957 (1999), the Court of Appeals addressed whether a claim for conversion could be made for intangible property rights. The Court stated that "[t]he original common law rule was that a claim for conversion could not be sought unless the plaintiff's property was tangible," but this "rule has been modified over time and certain intangible property interests may now be recovered through a conversion claim." Id. at 560. The Court held that "the tort of conversion generally may extend to the type of intangible property rights that are merged or incorporated into a transferable document." Id. at 562. The Court refused, however, "to extend the tort further, to cover completely intangible rights . . . ." Id. Moreover, it held that, even when intangible property rights were merged into a document, the tort of conversion would not be extended "to situations in which the relevant document itself has not been transferred." Id.