been applied to claims implicating that right. See Cardtoons, L.C. v. Major League Baseball Players Ass’n, 208 F.3d 885, 889 (10th Cir.2000) (quoting Video Int’l Prod., 858 F.2d at 1084); Video Int’l Prod., 858 F.2d at 1084 (“There is simply no reason that a common-law tort can any more permissibly abridge or chill the constitutional right of petition than can a statutory claim such as antitrust.”) PMI’s Noerr-Pennington argument might well have merit in light of the cases applying Noerr-Pennington’s protection to state common law claims sounding in tortious interference, but we need not decide that issue here because the Workers failed to state such a claim, as explained in the Part II.G.l. above. H. Loss of consortium The Workers’ final claim is for loss 755 N.E.2d 384, 393 (2001) (<HOLDING>). Ohio courts have repeatedly held that the
holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any holding that the trial court properly dismissed the lossofconsortium claim brought by the plaintiffs wife where it was derived from the plaintiffs emotional distress claim and involved no bodily injury to the plaintiff holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute holding that a plaintiff may recover damages for emotional distress caused by observing the negligently inflicted injury of a third person if but only if said plaintiff 1 is closely related to the injury victim 2 is present at the scene of the injury producing event at the time it occurs and is then aware that it is causing injury to the victim and 3 as a result suffers serious emotional distress recognizing that when a defendants negligence causes bodily injury the plaintiff can recover damages for past present and future medical expenses bodily injury and emotional distress