One type of Wisconsin Instruction to Jury that refusal to deliver goods after demand and tender of freight and storage charges can constitute conversion is based on the concept of depriving the rightful owner of their property. In such cases, the instruction would detail how the act of withholding the goods, despite the demand and tender of payment for freight and storage charges, can be considered as a conversion. This instruction aims to educate the jury on the legal definition and consequences of conversion in the context of refusing to deliver goods. Another type of instruction may focus on the key elements required to establish conversion in this specific scenario. It could outline that for the refusal to constitute conversion, there must be a lawful demand made by the rightful owner for the goods, a tender of payment for the freight and storage charges, and an intentional denial or withholding of the goods by the defendant. This instruction highlights the importance of fulfilling these essential elements for the plaintiff to successfully prove conversion. Furthermore, a detailed Wisconsin Instruction to Jury might also incorporate relevant keywords such as "ownership rights," "lawful demand," "tender of payment," "wrongful withholding," "deprivation of property," and "unjust enrichment." By incorporating such keywords, the instruction ensures that the jury is guided to consider essential legal elements and concepts while assessing the evidence and reaching a verdict in cases involving refusal to deliver goods after demand and tender of freight and storage charges.