Judge Davis Applies Delaware Law to Tortious Interference Claim, Finding No Conflict
September 14, 2021
Publication| Commercial Litigation
In KT4 Partners LLC v. Palantir Technologies, Inc., C.A. No. N17C-12-212 EMD CCLD, Judge Davis granted in part and denied in part the defendants’ motions for summary judgment. The plaintiffs filed suit alleging that the defendants tortiously interfered with a prospective business relationship the plaintiffs had with CDH Investments (“CDH”) to sell the plaintiffs’ stock through a secondary securities transaction. The plaintiffs also alleged that the defendants conspired to steer CDH away from the plaintiffs so that the defendants could appropriate the stock transaction for themselves. The parties disputed which state’s law would apply to the tortious interference claim.
Applying Delaware’s conflict-of-law principles, Judge Davis determined that Delaware law applied to the parties’ dispute because there was no actual conflict between Delaware and California law on the legal standards governing the case. Alternatively, the Court held that if there was a conflict, Delaware law would nevertheless apply because it had the “most significant relationship” to the case.
Judge Davis, applying Delaware law, went on to grant in part the motions for summary judgment to the extent that the plaintiffs sought to bring claims over which the Court lacked subject matter jurisdiction. In all other respects, the Court denied the defendants’ motions, finding that genuine issues as to material facts precluded summary judgment.
Analysis: This case provides a thorough analysis of Delaware’s conflict-of-law framework. In short, if there is no conflict between the law of the competing jurisdictions, the Court will apply Delaware law. If there is a conflict, the Court applies the “most significant relationship” test.