Franklin v. Dynamic Details, Inc., 116 Cal. App. 4th 375 (2004)

Bryan Franklin and Franklin-Choi Corporation (FCC) sued Dynamic Details, Inc. (DDi) and Jim Axton for defamation and tortious interference after Axton sent three e-mail messages to companies with which Franklin and FCC did business; the e-mail messages accused Franklin and FCC of plagiarism and violation of copyright laws, among other things. The trial court granted summary judgment to DDi and Axton. The Court of Appeal affirmed the judgment on the ground that Axton’s e-mail messages merely expressed Axton’s opinions and disclosed all of the provable facts supporting those opinions. The Court also affirmed summary judgment of the interference claims on the ground that Franklin and FCC had failed to establish a causal nexus between Axton’s e-mail messages and any damages or other harm suffered by FCC.