Well... I would suppose any argument could be made. And when the judge stops laughing you could ask him why it didn't work.
Well, if a court can decide that Burger King was negligent in its duty to protect its customers by failing to make its restaurants "car-proof", why couldn't it rule that a title search is an "improvement"?
http://www.state.il.us/court/opinions/SupremeCourt/2006/June/Opinions/Html/100372.htm
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