Reminder: fraudulent inducment requires specificity in the allegations

A recent case out of the Southern District of New York, Optima Media Group Ltd. v. Bloomberg L.P., 17-cv-1898 (AJN), reminds us that fraud causes of action, including fraudulent inducement to enter into a contract, need to be pled with specificity.

In the case, Bloomberg alleged that it had been fraudulently induced to enter into the contract based on alleged misrepresentations made by “Optima’s head, Rotimi Pedro, and his principal advisers” made “in a series of communications” “during [the] negotiations.” This was not enough specificity. These allegations do not identify exactly: who provided these alleged misrepresentations, where they were made, how they were made, or when they were made. For instance, there was no indication whether the statements were made “in person, over the phone, or by email.” Failure to specify the exact speakers was problematic in and of itself, and especially problematic in view of the failure to specify the location, method, or time frame of the alleged misrepresentations. Therefore, the court dismissed the claim. (Other of Bloomberg’s claims survived.)