GreenGro Technologies Inc (GRNH)

[Matruhina]

Common-Law Fraud by Misrepresentation

Generally, common-law fraud has the following elements:

1. The defendant made a misrepresentation of fact or false promise to the plaintiff.

2. The misrepresentation was material.

3. The misrepresentation was false.

4. The defendant (a) knew the misrepresentation was false when he made it, or (b) did not know whether the misrepresentation was true or false, but made it recklessly as a positive assertion, or (c) had no intention to perform the promise at the time he made it.

5. The defendant made the misrepresentation or promise with the intent that the plaintiff act on it.

6. The plaintiff relied on the misrepresentation or promise.

7. The misrepresentation or promise cause injury to the plaintiff.