No Interference with Prospective Business Relations Where Misconduct Directed at Plainitiff

On October 13, 2015, the First Department issued a decision in RXR WWP Owner LLC v. WWP Sponsor, LLC, 2015 NY Slip Op. 07447, affirming the dismissal of a claim for tortious interference with prospective business relations because "[c]onduct constituting tortious interference with business relations is conduct directed not at the plaintiff itself, but at the party with which the plaintiff has or seeks to have a relationship. Here, plaintiff alleges that [a non-party] would have granted plaintiff further extensions of the closing under the Contribution Agreement if [the defendants] had not offered [another defendant] a higher price for an interest in Holdings, which [the defendants were] able to do only because [they] wrongfully used plaintiff's confidential materials. Plaintiff's claim fails, because [the defendants] engaged in no wrongful conduct directed at [another defendant], as opposed to plaintiff: [they] merely offered [another defendant] a higher price for an interest in Holdings, which is not wrongful." (Internal quotations and citations omitted) (emphasis added).