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This article focuses on the qualifying as plaintiff in an action for a conversion. The word "conversion" as ordinarily used in the opinions of the common law judges has a sinister connotation. The distinguishing characteristic of an action of trover was that the successful plaintiff recovered from the defendant the full value of the property in question. In trespass and in actions on the case other than trover, the successful plaintiff sometimes recovered the full value, but frequently recovered much less than the full value. It was the measure of damages in trover that led plaintiffs who complained of wrongs with respect to personal property to seek to maintain actions of trover.