to paint its interpretation of improper means with too fine a brush, particularly in light of the fact that the Geltman Court cited favorably to the Restatement (Second) of Torts § 767. Id. at 817 n. 10, 551 N.E.2d 20. Comment c to that section states, in pertinent part, that: Violation of recognized ethical codes for a particular area of business activity or of established customs or practices regarding disapproved actions or methods may also be significant in evaluating the nature of the actor’s conduct as a factor in determining whether his interference with the plaintiffs contractual relations was improper or not. Restatement (Second) of Torts § 767 emt. c (1979). Sister state courts are in accord. See, e.g., Toney v. Casey’s General Stores, Inc., 460 N.W.2d 849, 853 (Iowa 1990) (<HOLDING>); Top Service Body Shop, Inc. v. Allstate Ins.,
holding that with respect to tortious interference recognized standards of business ethics and business customs and practices are pertinent holding that where both defamation and tortious interference claims are pled and are based on same facts minnesota law requires the application of the actual malice standard to tortious interference claims holding that a defendant could not be liable for tortious interference with a business relation where the defendant merely exercised its legal rights holding that the delayed discovery doctrine is not applicable to actions for tortious interference with business relationships defamation or unfair and deceptive trade practices holding that the first element in a prima facie case of tortious interference with prospective business advantage is the existence of business expectancy