720 (1978), the court found that an article stating that the plaintiff paid agents of foreign governments to win contracts was not actionable under the UDTPA because it impugned the plaintiffs integrity, rather than the quality of his services as an executive. See also Republic Tobacco, L.P. v. N. Atl. Trading Co., 254 F.Supp.2d 985, 998 (N.D.Ill.2002). Unlike the statement in Crinkley, the statement at issue in this case impugns the quality of M & R’s business and services. Stating that M & R is bankrupt directly attacks the quality of M & R’s business and indirectly undermines the quality of M & R’s services — an insolvent company cannot reliably deliver on-going services. See also Zahran v. Nat’l Guardian Life Ins. Co., No. 90-C-907, 1993 WL 116738, at *3 (N.D.Ill. April 19, 1993) (<HOLDING>). Accordingly, we find that count four properly
holding denial of deserved rise in performance rating may be actionable holding implied false certifications must be material to the governments payment decision in order to be actionable under the false claims act holding statement that plaintiff was antisemitic not actionable holding that accurate statements about past performance are not actionable under the securities laws holding that a false statement about a credit rating is actionable under the udtpa