In Kremen v. Cohen (337 F3d 1024 [9th Cir 2003]), the defendant was accused of stealing plaintiff's Internet domain name by falsely informing the Internet domain name registrar that the plaintiff abandoned the name, and then taking it for himself. The court reversed a district court dismissal of plaintiff's conversion claim on intangibility grounds, stating that "this rationale derives from a distinction tort law once drew between tangible and intangible property: Conversion was originally a remedy for the wrongful taking of another's lost goods, so it applied only to tangible property. Virtually every jurisdiction, however, has discarded this rigid limitation to some degree." (Id., at 1030.) The court concluded that "Kremen's domain name falls easily within this class of property . . . That it is stored in electronic form rather than on ink and paper is immaterial." (Id., at 1033-1034.)