held that the alleged contracts on which JLGAI relies are unenforceable. For this reason, JLGAI’s fraudulent inducement claim fails. Id. We overrule JLGAI’s fourth point of error. In its fifth point of error, JLGAI contends the trial court erred in granting summary judgment on its fraud claim. The trial court ruled that there was no competent summary judgment of reliance damages. The statute of frauds bars fraud claims seeking to recover as damages the benefit of a bargain unenforceable under the statute of frauds. Haase, 62 S.W.3d at 799. The statute of frauds, however, does not a bar a claim for fraud to the extent a party seeks reliance or out-of-pocket damages because such damages are not part of the benefit of the alleged bargain between the parties. Haase, 62 S.W.3d at 799-800 (<HOLDING>). Conclusory statements in an affidavit
holding that despite the fact that the statute of frauds prevents enforcement of the agreement a plaintiff can recover outofpocket damages incurred in reliance on the alleged false representation holding that the statute of frauds operates even when there has been reliance on a promise recognizing circumstances that justify enforcement of a promise unenforceable under the statute of frauds holding that the statute of frauds bars a breach of contract claim based on an oral agreement to enter a future employment contract that would need to meet the statute of frauds holding that plaintiff failed to prove reasonable reliance on a false statement