Extract to table

A plaintiff claiming tortious interference with prospective economic advantage, as opposed to interference with an existing contractual relationship, must demonstrate that the defendant employed independently wrongful means

Vantor's "Unfairness" Theory Fails the Applicable Balancing Test To the extent Vantor argues that Cascade's conduct was "unfair" under the Section 17200 framework, it must satisfy the applicable standard for "unfairness" in competitor cases

Critically, California law imposes an additional requirement on claims for interference with prospective economic advantage that does not apply to claims for interference with existing contractual relations: the plaintiff must demonstrate that the defendant engaged in conduct that was "independently wrongful"—i

The conduct must be "proscribed by some constitutional, statutory, regulatory, common law, or other determinable legal standard

Even taken in the light most favorable to Vantor—as the Court must on a motion for summary judgment—these fourteen emails do not establish independently wrongful conduct

3d 64, 79 (holding that damages for lost profits must be proven with "reasonable certainty" and may not be based on "speculation or conjecture")