The following excerpt is from Albert v. Loksen, 239 F.3d 256 (2nd Cir. 1999):
Under New York law, the elements of a tortious interference claim are: (a) that a valid contract exists; (b) that a "third party" had knowledge of the contract; (c) that the third party intentionally and improperly procured the breach of the contract; and (d) that the breach resulted in damage to the plaintiff.
Finley v. Giacobbe, 79 F.3d 1285, 1294 (2d Cir. 1996).
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