On Aug. 7, 2026, the Appeals Court of Massachusetts vacated a Chapter 93A judgment in Antokal v. Spring Valley Country Club, Inc., holding that the trial court’s findings were insufficient to establish liability based on negligent misrepresentation. The appeals court held that such business falls squarely within the commercial transaction requirement of Chapter 93A. On the second argument, the appeals court found the trial judge’s findings insufficient to sustain Chapter 93A liability. The court held that negligent misrepresentation can support a Chapter 93A violation if it is “so extreme or egregious” as to rise to that level. This case highlights that negligent misrepresentation may support the basis for Chapter 93A liability in some circumstances; where it does, courts would look for conduct that rises to an “extreme and egregious” level — a threshold that is sometimes difficult to meet.