"Defendant (a Freed venture called 108 N. State Retail LLC) represented to Lululemon that Apple would be opening for business at the shopping center, that Apple would be located immediately next to Lululemon, and that Apple had executed a lease," the lawsuit says. "When defendant made these representations, defendant knew they were false and made them with the intent to deceive and defraud and induce Lululemon to execute the lease."