A:

A plaintiff alleging conspiracy to defraud should prove the following elements:

• The existence of an actionable conspiracy;
  
  

  The defendant's membership in conspiracy;

  The occurrence of a substantial act or substantial effect in furtherance of the conspiracy in the forum state;

  The defendant's actual or constructive knowledge of act in forum state or that act outside the state would have effect in state; and

  That act in, or effect on, the forum state was a direct and foreseeable result of conduct in furtherance of conspiracy.