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940D. The Barclays Improper Appropriation, by which Barclays seized at least $48,459,635from Plaintiff that Barclays was contractually required to return, breached Barclays’ contractualobligations to Plaintiff under the Charge on Cash Agreement and the ISDA Master Agreement.940E. To the extent that Plaintiff owed Barclays any contractual duties in connection withthe Charge on Cash Agreement or ISDA Master Agreement other than payment of sums for whichBarclays held more than sufficient collateral, Plaintiff had performed them at the time of theBarclays Improper Appropriation.940F. Accordingly, Plaintiff is entitled to judgment against Barclays in an amount to beproved at trial, but not less than $48,459,635 plus interest and attorneys’ fees.COUNT 25B(Conversion)940G. The allegations of paragraphs 1 through 940F of this Complaint are incorporatedherein by reference.940H. By the Barclays Improper Appropriation, Barclays seized at least $48,459,635 inspecially segregated funds that belonged to Plaintiff and not Barclays.940I. The Barclays Improper Appropriation intentionally and improperly interfered withPlaintiff’s ownership of and/or denied Plaintiff’s rights to specific property and wrongfullyconverted that property to Barclays’ use.940J. Accordingly, Plaintiff is entitled to judgment against Barclays in an amount to beproved at trial, but not less than $48,459,635 plus interest and attorneys’ fees.COUNT 25C(Unjust Enrichment)940K. The allegations of paragraphs 1 through 940J of this Complaint are incorporatedherein by reference.604041v1/007457-348-