The most important class of trespasses to personal property are those known as conversions. Every act of control over personal property, without the owner's authority, and in violation of his rights, is a conversion.5 Sawing trees belonging to another into logs is a conversion,6 as is also making wheat into flour,7 or the adulteration of liquor by a carrier.8 It is a convertom then prevailing throughout all England small trespasses were to be presented in the seignorial courts, and that for offenses there cognizable, one was not to sue out a common law writ. It is largely for this reason, no doubt, that early instances are wanting of the use of trespass vi et armis for a mere injury to personalty unconnected with a destruction or asportation." Street's Foundation of Legal Liability Volume I, p. 15, note 2.

3 See subject of Common Law Pleading, Volume XI, Subject 34.

4 American and English Ency. of Law, Vol. XXVIII, p. 587. "A claim of dominion, an intention being indicated to interfer with the goods under pretense of any right or authority, amounts to a contructive trespass." Haythorn vs. Rush-forth, 19 N. J. L., 165, 38 Am. Dec, 540.

5 Needham vs. Rawbone, 6 I. B.,

771 note, b 51 E. C. L., 771; Conner vs. Allen, 33 Ala., 515; Monmouth First National Bank vs. Dunbar, 19 111. App., 558; Scott vs. Perkins, 28 Me., 22, 48 Am. Dec, 470; Industrial, etc., Trust vs. Tod, 170 N. Y., 233; Arnold vs. Kelly, 4 W. Va., 646.

6 Baker vs. Wheeler, 8 Wend.

(N. Y.), 505, 24 Am. Dec, 66.

7 Mayer vs. Springer, 192 111., 270.

8 Dench vs. Walker, 14 Mass., 500.

sion to collect a bill or note belonging to another without the authority of the owner,9 or to sue a note to judgment, without such consent.10 The cancellation of a certificate of membership in a Board of Trade,11 or the wrongful cancellation of stock,12 amounts to a conversion.

Not every tortious act, however, which effects personal property is a conversion. Damaging personal property, or even interference with the owner's use of the property, without depriving him of its possession does not amount to a conversion.13 Wrongful use of the chattel of another is not a conversion where there is no denial of the owner's title.14 Assertion of ownership unaccompanied by any act of ownership will not amount to a conversion.15 To constitute conversion, there must be either an actual conversion of the property to the use of the defendant, or a constructive conversion by failure to deliver up the property on demand.16 As a general rule, the question of intention is immaterial in determining whether or not there has been a conversion.17