in the Nelson affidavit considered by the court was that MHA believes that some of the work, which Gear was required to complete under its contract, remains incomplete. 5 Reliance is also an essential element of a claim for fraud. See Zimmerman v. Kent, 31 Mass.App.Ct. 72, 77 (1991). Since Gear has failed to set forth specific facts from which a reasonable jury could find reliance, Goba is also entitled to summary judgment on Gear’s fraud claim. 6 Although Massachusetts has yet to define what conduct constitutes “more than a minor or insignificant business relationship," the Supreme Judicial Court, the Appeals Court and the federal courts have tended to find such a relationship where the defendant played an active role in the underlying transaction. Compare Kattar, 433 Mass. at 14-15 (<HOLDING>); Reisman, 57 Mass.App.Ct. at 125 (holding that
holding that an insurers defenses against the mortgagor could not be asserted against the mortgagee holding that an abutter could not bring a 93a claim because there was no business relationship with the defendant holding that despite the absence of a contractual relationship and no formal authority over the mortgagor since the defendant was a member of the mortgagors inner circle the mortgagee could sustain his 93a claim holding that a mortgagor in possession is not a fiduciary of the mortgagee within the meaning of the bankruptcy act even though the mortgagor has obligated himself to keep the security intact holding the assignment of the mortgage once the original grant by the mortgagor to the mortgagee has been perfected does not involve a transfer of the property of the debtor 