The Sixth District Court of Appeal recently addressed what it takes for someone to beat an alter ego claim on a motion for summary judgment.  In Zoran Corp. v. Chen, the plaintiff sued several companies and an individual for amounts owed to the plaintiff for equipment that it had sold.  A central theory of the complaint was that the individual directly controlled and dominated the defendant companies and thus the companies were his alter egos.  The trial court granted summary judgment for the individual defendant and the Court of Appeal reversed.  Given the fact specific nature of the court's review, the opinion doesn't lend itself to generalizations.  However, the case does illustrate that defendants can have a tough time getting rid of alter ego claims on summary judgment.