any New York federal or state court that has held that special damages is an element of an unfair competition claim.”). Simply alleging that defendant diverted plaintiffs customers and business is sufficient to show special damages. See CA, Inc., 621 F.Supp.2d at 54; Out of the Box Promotions, LLC v. Koschitzki, 55 A.D.3d 575, 866 N.Y.S.2d 677, 681 (2d Dep’t 2008). Although unfair competition often involves misappropriation of trade secrets or ideas, a claim may be based on misappropriation of client lists, internal company documents, and business strategies “if wrongful or fraudulent tactics [are] employed.” Leo Silfen, Inc. v. Cream, 29 N.Y.2d 387, 328 N.Y.S.2d 423, 278 N.E.2d 636, 639 (1972); see also Milton Abeles, Inc. v. Farmers Pride, Inc., 603 F.Supp.2d 500, 503 (E.D.N.Y.2009) (<HOLDING>); Berman v. Sugo LLC, 580 F.Supp.2d 191, 209
holding that the first amendment does not by itself give rise to a cause of action for damages holding that cda  230 provided immunity from state unfair competition and false advertising actions holding that alleged violations of a state statute did not give rise to federal constitutional claims holding that misappropriation of a confidential distribution list of customers and subdistributors may give rise to a claim of unfair competition holding that failure to record an assignment does not give rise to a cause of action