to its trademark infringement and unfair competition claims). Consequently, defendant is entitled to summary judgment on plaintiffs chapter 93A claim. VIII. HALL’S COUNTERCLAIM In his counterclaim, Hall alleges that The Black Dog Tavern, through its September 5, 1991 letter to Famous Sportswear and its subsequent commencement of this action, intentionally and wrongfully interfered with his advantageous business relationship with Famous Sportswear. He also claims that plaintiffs interference, which allegedly cost him over 860 T-shirt sales, constituted unfair competition in violation of Mass.Gen.L. ch. 93A. To prevail on either theory, Hall must prove that plaintiffs actions were somehow improper. See United Truck Leasing Corp. v. Geltman, 406 Mass. 811, 815-16, 551 N.E.2d 20, 23 (1990) (<HOLDING>); Levings v. Forbes & Wallace, Inc., 8
recognizing the tort of wrongful interference with anothers business relations holding absent some independent tort contract agreement voluntary assumption of duty or special relationship of the parties the new tort of the intentional interference with a prospective civil action by spoliation of evidence should not be recognized in kansas holding that under colorado law tjortious interference with a prospective business relation requires a showing of intentional and improper interference preventing formation of a contract holding that tortious or deliberate intent to harm a plaintiffs business relationship is not alone sufficient to support an intentional interference claim there must also be proof that the defendants interference was accomplished through improper means holding improper conduct to be an element of the tort of intentional interference with an advantageous business relationship