“Tellingly, though, the lawsuit didn’t allege theft or its civil-law cousin — “conversion,” in lawyers’ language. It alleged only unjust enrichment. That’s probably because under current law and precedent, proving that Thermo Fisher Scientific or Johns Hopkins took anything from Lacks illegally would have been difficult or impossible..”

https://www.nytimes.com/2023/08/04/opinion/henrietta-lacks-cells-property.html