not purchase the homes as businesses. The defendants have the better argument. The thrust of the complaint is that the plaintiffs’ investment in rental properties in Detroit resulted in a loss to them, either because the defendants misrepresented the condition of the properties and the likely rate of return or they breached their contracts. Under Michigan law, “if an item is purchased primarily for business or commercial rather than personal purposes, the MCPA does not supply protection.” Zine v. Chrysler Corp., 236 Mich.App. 261, 273, 600 N.W.2d 384, 393 (1999); see also MacDonald v. Thomas M. Cooley Law Sch., 880 F.Supp.2d 785, 792 (W.D.Mich.2012). Moreover, the MCPA does not apply to investors. Quartell v. Great Lakes Bancorp, 183368, 1996 WL 33347624 (Mich.Ct.App. Dec. 17, 1996) (<HOLDING>). The plaintiffs have failed to state a valid
holding that  10113aa does not alter the requirement that the property in question be real property in order for the antimodification provision to apply holding utpa does not apply to real property sales holding that  1447c does not apply to counsel holding that the mcpa does not apply to property purchased for investment purposes holding that title ii does not apply to the states