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2023
May
Annual Wolfson Family Resilience Scholarship Awarded
Supreme Court Rules Section 363(m) of Bankruptcy Code Is Not Jurisdictional
April
Scott A. Wolfson Elected Director of American College of Bankruptcy Foundation
March
Logan T. Grizzell Joins Wolfson Bolton Kochis as Associate Attorney
Thomas J. Howlett Joins Wolfson Bolton Kochis, Leads Real Estate Practice
February
Scott Wolfson Obtains Back-to-Back Victories in Sixth Circuit Court of Appeals
Michelle H. Bass Business Highlight Quoted in CNBC Article
Scott A. Wolfson Featured in Latest American Bankruptcy Institute Industry Viewpoints Segment
January
Scott A. Wolfson Speaks at the Economic Club of Marquette County
Wolfson Bolton Kochis Announces Kenton Bednarz as its New Practice Lead for M&A, Corporate and Emerging Growth
Wolfson Bolton Starts the New Year With a New Name – Wolfson Bolton Kochis PLLC
2022
December
Two Wolfson Bolton Partners Speak at American Bankruptcy Institute’s Winter Leadership Conference
November
UCC Seriously Misleading - Is an Abbreviation of a Borrower’s Name Fatal to Perfecting a Security Interest?
Wolfson Bolton Earns Tier 1 Rankings in 2023 Edition Of U.S. News – “Best Law Firms” List
September
Delaware Court Holds Anti-Reliance Provisions Do Not Bar Fraudulent Inducement Claim
Wolfson Bolton Retained in Large Bankruptcy Case
August
Four Wolfson Bolton Attorneys Selected by Best Lawyers 2023
Wolfson Bolton Partners Recognized by Super Lawyers and One Named to Michigan Top 100
July
Chapter 11’s 547(b) Amendment: What Does “Due Diligence” Mean for Preferential Payment Claw Backs?
Boyce Hydro Liquidating Trustee Scott A. Wolfson Interviewed by ABC12 about Claim Deadline
June
Michelle H. Bass Speaks at the American Bankruptcy Institute’s 29th Annual Central States Bankruptcy Workshop
Michelle H. Bass Authors Article in July 2022 American Bankruptcy Institute Journal
Is an Unsigned Contract Containing an Arbitration Clause Enforceable?
Kenton M. Bednarz Joins Wolfson Bolton PLLC
Michelle H. Bass Speaks at ICLE’s 62nd Annual Probate & Estate Planning Institute
Michigan Supreme Court Allows Greater Flexibility in Alternative Dispute Resolution
Scott A.Wolfson Ranked in the Chambers and Partners USA Guide 2022
May
Annual Wolfson Family Resilience Scholarship Awarded
April
Shareholder Suits after Cash-Out Mergers: Direct, Derivative, or Dead on Arrival?
Expiration of the Coronavirus Aid, Relief, and Economic Security (CARES) Act
Michelle H. Bass Named Partner at Wolfson Bolton
February
UP200 Sled Dog Races
Practice Updates
2021
November
Wolfson Bolton Earns Tier 1 Rankings in 2022 Edition Of U.S. News – “Best Law Firms” List
Kelsey Postema Sworn in as a Member of the Michigan Bar
October
Chapter 13 Bankruptcy - What is it and what are the advantages?
Credit Counseling – What is it and how can it help?
Michelle Bass Achieves Board Certification in Consumer Bankruptcy Law
Understanding Chapter 7 Bankruptcy
September
3 Things to Do After Bankruptcy
Client Alert: GM Imposes New Warranty Chargeback Process
August
5 Bankruptcy Myths
When is bankruptcy the right option?
Four Wolfson Bolton Attorneys Recognized by Super Lawyers and One Named to Michigan Top 100
Anthony J. Kochis Co-Authors Article in State Bar of Michigan Litigation Newsletter
Scott A. Wolfson Named a Lawyer of the Year 2022
Three Wolfson Bolton Attorneys Selected by Best Lawyers 2022
July
Bankruptcy Dos and Don'ts
Filing for Bankruptcy: Don't Wait Too Long
Federal Courts Broadly Construe Subchapter V Eligibility
June
Scott A. Wolfson Featured in Latest American Bankruptcy Institute Industry Viewpoints Episode
Sixth Circuit Holds Arbitrability Must Be Decided By Arbitrator, Not AAA Administrator
May
Chapter 7 Bankruptcy - What is it and how does it work?
Court Rebuffs NRA’s Bankruptcy Petition As Filed in Bad Faith
April
Bankruptcy Courts Use Force Majeure Clauses in Commercial Leases to Provide Relief during the Pandemic
Importers May Still Be Able to File Claims for Refunds of Section 301 China Tariffs
Michelle H. Bass Named to Crain’s 2021 Notable Women in Law
Eleventh Circuit Upholds Discharge Injunction to Prohibit Post-Discharge Suit for Collection of a Nondischargeable Debt
March
Third Circuit Confirms Triangular Setoffs Do Not Meet Mutuality Requirement of Section 553
SBA Issues Guidance on PPP Loans and Change of Ownership Transactions
February
Management Cannot Preclude Directors’ Access to Privileged Communications
January
Supreme Court: Mere Retention Of Property Does Not Violate Bankruptcy Automatic Stay
Federal Court Finds that OEM Purchase Order Does Not Necessarily Govern Parties’ Contract
2020
December
Anthony J. Kochis to Present on Strafford Webinar, “Section 523 Nondischargeability Litigation: Plaintiff and Defense Strategies
Court of Appeals Applies Michigan Law to Forum-Selection Clause, Regardless of Parties’ Choice of Law
November
Wolfson Bolton Earns Tier 1 Rankings in 2021 Edition Of U.S. News – “Best Law Firms” List
October
Scott A. Wolfson Elected as a Fellow of the American Bar Foundation
September
Five Wolfson Bolton Attorneys Recognized by Super Lawyers and One Named to Michigan Top 100
Vonica Sallan Joins Wolfson Bolton as Associate Attorney
August
Scott A. Wolfson and Peter C. Bolton Selected to The Best Lawyers in America 2021
Beach Mold & Tool, Inc. Named Transaction of the Year by Turnaround Management Association
Lara Phillip Selected to The Best Lawyers in America 2021
July
Scott A. Wolfson Authors Article in July 2020 State Bar of Michigan Journal
June
Wolfson Bolton Confirms First Small Business Bankruptcy Plan in Michigan under New Law
Scott A. Wolfson Named Entrepreneur’s Organization Detroit Chapter President
Kelsey Postema Joins Wolfson Bolton PLLC
April
Wolfson Bolton Obtains Significant Victory in Sixth Circuit Court of Appeals
What Happens After a Business Files For Chapter 11 Bankruptcy?
March
Chapter 11 Bankruptcy Basics
Goodrich Quality Theaters Files for Bankruptcy
Wolfson Bolton Featured in March 2020 Michigan Manufacturers Association Magazine
February
The Impact of the Coronavirus on the Supply Chain
What Does the Small Business Reorganization Act of 2019 (SBRA) Mean for Small Businesses?
John R. Stevenson Joins Wolfson Bolton PLLC
January
Lara Fetsco Phillip Joins Wolfson Bolton PLLC
2019
December
Scott A. Wolfson Invited to Join American College of Bankruptcy As Fellow
October
Wolfson Bolton Opens New Office In Marquette, Michigan
Scott A. Wolfson Appointed to American Arbitration Association’s National Roster of Commercial Arbitrators
September
Super Lawyers Recognizes Four Wolfson Bolton Attorneys
Scott A. Wolfson Appointed Member of American Bankruptcy Institute Journal Editorial Board
August
Scott A. Wolfson and Peter C. Bolton Named to Best Lawyers 2020
July
Michelle Bass Honored by Michigan Lawyers Weekly as 2019 Woman in the Law
June
Wolfson Bolton Celebrates 10th Anniversary
Suzana Dema Named 2019 Unsung Legal Hero By Michigan Lawyers Weekly
Michelle H. Bass Speaks at American Bankruptcy Institute 26th Annual Central States Bankruptcy Workshop
May
Michelle H. Bass Authors Article in May 2019 American Bankruptcy Institute Journal
Annual Wolfson Family Resilience Scholarship Awarded
Scott A. Wolfson and Rachel Walton Author Article in May 2019 American Bankruptcy Institute Journal
Supreme Court: Trademark Use Contract Rights Survive Rejection
March
Eric A. Zacks Co-Wrote Casebook Titled “Contracts In Context: From Transaction To Litigation”
Newsletters
2018
December
Delaware Supreme Court Holds Operating Agreement May Void Related Party Contract
Wolfson Bolton Featured In December 2018 Issue Of Michigan Manufacturers Association Magazine
November
Anthony J. Kochis Speaks at Hon. Steven W. Rhodes Consumer Bankruptcy Conference
Wolfson Bolton Obtains Summary Judgment in Michigan Sales Representative Commission Act Case
Sixth Circuit Establishes a Two-Prong Test for Finality in Bankruptcy Appeals
October
Sixth Circuit Bankruptcy Court Discharges Student Loan Debt for “Functionally Disabled” Debtor
Law Firm’s Retainer Not Required to be Returned to Bankruptcy Estate
WB Obtains Preliminary Injunction for Client Enforcing Non-Compete Agreement
Sixth Circuit Holds That Judgment Can Have Preclusive Effect Despite Being Set Aside
September
Bankruptcy Court Disallows Secured Creditor’s Claim for Prepayment Penalty
Four Wolfson Bolton Attorneys Recognized by Super Lawyers and One Named to Michigan Top 100
August
The Best Lawyers in America Honors Scott A. Wolfson and Peter C. Bolton
July
Claims Traders Beware, Anti-Assignment Clauses May Bite
Wolfson Bolton Represents Nassar Survivor
Michelle H. Bass Authors Article Featured in August 2018 Issue of the American Bankruptcy Institute Journal
June
U.S. Supreme Court: False Statements about a Single Asset Must Be in Writing for Nondischargeability
Sixth Circuit Suggests Zero Tolerance for Penalties Incurred In Connection with Fraud
Scott A. Wolfson to Speak at Wolfson Bolton Sponsored American Bankruptcy Institute Conference
Anthony J. Kochis Attends State Bar of Michigan Litigation Summer Conference
Scott A. Wolfson Recognized by DBusiness as 2018 Top Lawyer in Fields of Mediation and Bankruptcy and Creditor/Debtor Rights Law
Counterclaims Asserted by Borrower Not a Defense to Guarantors' Liability
May
Annual Wolfson Family Resilience Scholarship Awarded
April
FCA Prohibited from Asserting Setoff Rights Under Accommodation Agreement
Bankruptcy Court Awards Nearly $100K in Sanctions Against Individual Asserting Estate’s Claims
Post-Bankruptcy Transfers Governed By Date Of Honor Rule
U.S. Supreme Court Narrows Bankruptcy “Safe Harbor” Protections in Clawback Litigation
Michelle H. Bass and Kathleen A. Stearns Join In Reestablishing Michigan Network of IWIRC
March
Uniform Receivership Act Enacted in Michigan
February
Uncodified Best Practices in Consumer Bankruptcy Cases in the Digital Age
Update on U.S. Department of Transportation Connected Vehicle Pilots
Sixth Circuit Clarifies Requirements to Preserve Claims in Bankruptcy
January
Scott A. Wolfson and Charles M. Moore Author Article in January 2018 American Bankruptcy Institute Journal
Administrative Expense Allowed for Claim Against Assignee for the Benefit of Creditors
2017
December
Reclamation Claim, Even If Valid, Is Primed By Prior Floating Lien
Update On NAFTA Negotiations
Significant Assets / Significant Debts – Chapter 13 For The High-Income Earning Individual
Challenge to Trustee’s Sale of Avoidance Actions Moot
November
Ninth Circuit Determines De Facto Control is not Dominion in Fraudulent Transfer Case
Sixth Circuit Stands Alone on Chapter 13 Voluntary Retirement Contributions
Wolfson Bolton Earns Tier 1 Rankings In 2018 Edition Of U.S. News - Best Lawyers "Best Law Firms" List
October
Violation of Intercreditor Agreement Costs Senior Lender its Priority
September
Sixth Circuit Narrows Ability to Use Antitrust Violations as an Affirmative Defense
Fraud Of A Greater Magnitude: Sixth Circuit Reinforces High Bar For Relief Under Rule 60(d)(1)
Super Lawyers Recognizes Four Wolfson Bolton Attorneys
Michelle H. Bass Joins Wolfson Bolton PLLC
Ninth Circuit Allows Trustee’s Fraudulent Conveyance Suit against IRS
August
Adverse-Domination Doctrine Does Not Toll Statute of Limitations For Claims Committee Could Have Brought
Tenants Beware: Bankruptcy Sale May Terminate Your Lease
The Best Lawyers in America Honors Scott A. Wolfson and Peter C. Bolton
Scott A. Wolfson Named to American Bar Association Leadership
Secured Lender's Dispositive Motion Denied in Sports Authority's Consignment Controversy
July
Bankruptcy Court Holds Case Subject To Dismissal When Reorganization Depends On Income Derived From Sale Of Marijuana
Court Of Appeals Affirms Trial Court's Decision To Bar Witnesses After Party Misses Disclosure Deadline
Scott Wolfson Speaks at Federal Bar Association Bankruptcy Seminar
June
Sixth Circuit Holds "Insured-Versus-Insured" Exclusion Applies to Liquidating Trustees
Michigan Supreme Court Issues Important Ruling in LLC Member Oppression Case
May
Supreme Court Holds Time-Barred Bankruptcy Proof of Claim Does Not Violate Fair Debt Collection Practices Act
Michigan Supreme Court Permits Jury Waiver Regarding Award of Attorney Fees
Anthony J. Kochis To Speak At 24th Annual Central States Bankruptcy Workshop
Annual Wolfson Family Resiliency Scholarship Awarded
Scott A. Wolfson Appointed Hearing Panelist for Michigan Attorney Discipline Board
Scott A. Wolfson Appointed Hearing Panelist for Michigan Attorney Discipline Board
Sixth Circuit Holds Assignment of Rents Is Transfer of Ownership Under Michigan Law
April
Michigan Court of Appeals Holds That Not All Common-Law Unfair Competition Claims Are Preempted by Michigan Uniform Trade Secret
Supreme Court Rejects Structured Dismissals That Violate Bankruptcy Priority Distribution Scheme
March
Badges of Fraud Shift Burden of Proof to Judgment Debtor Defendant
Wolfson Bolton Retained as Committee Counsel in VPH Pharmacy Case
Intercreditor Agreement Enforced Despite Restructuring of Priority Debt
February
Sixth Circuit Court of Appeals Issues Lengthy Opinion Regarding Claims of Actual Fraud
Settlement Is Binding Despite Claim that Attorney Lacked Client Authorization
January
Bank’s Security Interest Does Not Attach to Chapter 11 Bankruptcy Retainer
Creditors’ Committee’s Legal Fees Not Subject to Pre-Confirmation Cap
Sixth Circuit: Bankruptcy Trustee’s Veil Piercing and Substantive Consolidation Claims Fail in Fraudulent Transfer Case
ABA's Business Law Today Publishes Anthony J. Kochis' Safe Harbor Article
WB Announces Creation of Mobility Practice Group
2016
December
Golf Channel Scores Bounce Back Birdie in Ponzi Scheme Fraudulent Transfer Case
Michigan Legislature Considers Replacing Uniform Fraudulent Transfer Act with Uniform Voidable Transactions Act
Anthony J. Kochis Selected to Up & Coming Lawyers Class by Michigan Lawyers Weekly
More Than They Barton’ed for: Plaintiffs Must Seek Authorization to Sue Committee Members under Barton Doctrine
November
Wolfson Bolton Earns Tier 1 Rankings in 2017 U.S. News – Best Lawyers® "Best Law Firms" List
Scott A. Wolfson Moderates American Bankruptcy Institute Panel on Depositions
Scott A. Wolfson and Adam L. Kochenderfer Named 2017 Top Lawyers
Sixth Circuit Denies Detroit Pensioners’ Appeal under Equitable Mootness Doctrine
Eleventh Circuit Court of Appeals Holds District Court Is Without Jurisdiction to Rule on Alleged Violation of Bankruptcy Discha
October
Receiver's Sale of Real Estate Free and Clear of Mortgages Upheld
September
Party Bound By Settlement Agreement's Terms Despite Failing to Sign It
Chapter 7 Trustee’s Civil Conspiracy Claim Survives In Pari Delicto Challenge
August
Court Permits Creditor to Set Off Administrative Expense against Preferential Liability
Anthony Kochis Receives TMA Detroit nextGen Top of the Class Award
ABA Business Bankruptcy Committee to Host Claims Trading Debate at the National Conference of Bankruptcy Judges
The Best Lawyers in America© 2017 Honors Peter C. Bolton
Scott A. Wolfson Named "Lawyer of the Year" for 2017
Bankruptcy "Blocking Director" of Michigan LLC Rejected
July
Unperfected Secured Creditor with After Acquired Property Clause Ruled Top Dog
Equitable Subrogation Appropriate Despite Payor Being Party to Mortgage
General Products Corporation Files Bankruptcy, Seeks Quick Sale of Assets
June
Restriction Prohibiting LLC’s Bankruptcy Filing Held Void
Scott A. Wolfson Delivers Commencement Address
Scott A. Wolfson to Speak at American Bankruptcy Institute’s Central States Conference
Divestiture Doctrine Inapplicable to Request for Stay Pending Appeal
May
Words Speak Louder Than Numbers
Supreme Court Broadly Interprets "Actual Fraud" Bankruptcy Discharge Exception
First Annual Wolfson Family Resiliency Scholarship Awarded
April
Michigan Court of Appeals Rules Circuit Court Did Not Have Jurisdiction Over Claim and Delivery Action
Michigan Bar Journal Publishes Scott A. Wolfson's Litigation Article
Scott A. Wolfson’s and Anthony J. Kochis’ Article on D&O Case Published by American Bankruptcy Institute Journal
Wolfson Bolton Sponsors Bar Charity Event
Fifth Circuit Upholds Surcharge against Secured Creditor Despite Failed Sale Efforts
March
American Bankruptcy Institute Releases Scott A. Wolfson’s Podcast Preview of Spring D&O Panel
Pre-Bankruptcy Lease Terminations May Constitute Avoidable Transfers
February
Michigan Court of Appeals Rules that Plaintiff Could Sue on Contract Despite Different Name on Invoice
Scott A. Wolfson Quoted in Crain’s Detroit Business on City of Detroit Preference Cases
Payments Made by Secured Creditors to Unsecured Creditors Not Subject to Priority Scheme
January
"Inquiry Notice" of Borrower’s Fraud Voids Bank’s Security for $312 Million Loan
Scott A. Wolfson to Speak at American Bankruptcy Institute’s Annual Spring Meeting
Bankruptcy Court Holds D&O Policy Proceeds Payable to Non-Debtors Not Estate Property
Great Lakes Comnet, Inc. and Comlink, L.L.C. File Bankruptcy, Eyeing Quick Sale of Assets
Community Involvement
2015
December
Scott A. Wolfson Quoted in Crain’s Detroit Business on City of Detroit Pre-Bankruptcy Preference Claims
Bankruptcy Court Did Not Err Allowing State Court Litigation against Debtor to Continue
November
City of Detroit Sues Vendors to Recover Millions in Preferential Payments
Forbearance Agreement Provides Sufficient Value
Wolfson Bolton PLLC Receives Tier 1 Rankings from U.S. News and Best Lawyers® 2016 "Best Law Firms"
October
Michigan Court of Appeals Holds “Exclusive” Contract Unenforceable
Super Lawyers Recognizes Four Wolfson Bolton Attorneys
Scott A. Wolfson on Cover of Michigan Super Lawyers 2015
Sixth Circuit Permits Administrative Claim for "Substantial Contribution" in a Chapter 7 Case
September
Court Denies Prepetition Lender’s Request for Stay Pending Appeal of Interim Financing Order
August
Trump Trumps Trump
Court Holds Subtenant Rent Payments Not Part of Farmer Jack Bankruptcy Estate
Peter C. Bolton and Scott A. Wolfson Recognized in Best Lawyers in America
July
Sixth Circuit Holds that Law v. Siegel Limits Bankruptcy Court Authority to Disallow Exemptions
June
Wolfson Bolton Wins Summary Judgment Holding Trust Bankruptcy Estate Property
U.S. Supreme Court Holds Bankruptcy Lawyers Not Entitled to Compensation for Defending Fees
Scott A. Wolfson Moderates American Bankruptcy Institute Panel
U.S. Supreme Court Overrules Debtors’ Ability to Void Underwater Junior Mortgages
May
Wolfson Bolton Retained as Committee Counsel in Lee Steel Corporation Case
"Convoluted" UCC Financing Statement Collateral Description Not "Seriously Misleading"
April
Business Social Media Accounts Are Property of the Bankruptcy Estate
District Court Reviewing Bankruptcy Court’s Proposed Findings of Fact and Conclusions of Law Need Not Accept Additional Evidence
March
Court Holds Chapter 11 Professional Fees not Subject to Disgorgement Despite Insolvency of Converted Chapter 7 Estate
Seventh Circuit Holds Free Exercise of Religion Is Not a Shield against Avoidance Actions
February
Reorganization Plan Discharging Debtor Did Not Discharge Obligations of Guarantors
Potential Chilling Effect Not Enough to Deny Right to Credit Bid
January
Potential Chilling Effect Not Enough to Deny Right to Credit Bid
Delaware Bankruptcy Court Dismisses Chapter 11 Filed As A Litigation Tactic
2014
December
Payments for Living Expenses No Bar to Actual and Constructive Fraud Claims
In Dillard v. Schlussel, No. 315485, 2014 Mich. App. LEXIS 1985, at *1 (Mich. Ct. App. Oct. 21, 2014), the Michigan Court of App
October
State Court "Penalty" Default Judgment Entitled to Preclusive Effect
September
Secured Creditor’s Right to Credit Bid Capped
August
No Right to Jury Trial in Michigan Shareholder Oppression Actions
July
Fourth Circuit Strikes Plan’s Non-Consensual Third-Party Release
June
Supreme Court Rules Bankruptcy Courts Can Adjudicate Stern Claims Subject To District Court Review
Michigan Court of Appeals Overrides Express Contract Language by Creating "Gap Filler"
Michigan Court of Appeals Refuses to Enforce Photocopied Promissory Note
May
Sixth Circuit Holds Bank’s Loss Payee Coverage Derivative
Sixth Circuit Holds Individual Chapter 11 Debtors Remain Subject to the Absolute Priority Rule
Sixth Circuit Holds Bankruptcy Court Has Constitutional Authority to Enter Final Judgment in Non-Discharge Action
April
Amendments to Michigan Court Rules Regarding Receivership to Take Effect May 1, 2014
March
Michigan Court of Appeals Refuses to Enforce Contract on Public Policy Grounds
Michigan Court of Appeals Holds “Outbidding and Outmaneuvering” Does Not Constitute Tortious Interference
February
Filing of Unauthorized UCC Termination Statement Held Ineffective
2013
December
Sixth Circuit Holds Notice to Creditor’s Attorney Insufficient to Allow Discharge of Debt
November
Secured Creditor Setoff Rights Clarified in Garnishment Context
Junior Creditor’s Assignment of Voting Rights Enforceable in Bankruptcy
October
Groeb Farms, Inc. Files Chapter 11 Bankruptcy, Pursues Quick Sale to Private Equity Firm
Court Confirms Secured Creditor’s Right to Purchase Collateral at Article 9 Sale
September
Sixth Circuit: Denial of a Bankruptcy Reorganization Plan Is Not a Final Order
Bankruptcy Court Rules That Pre-Petition Stay Waiver Can Be Considered In Determining "Cause" For Relief From Stay
August
Primary Issues to be Decided in the City of Detroit Chapter 9 Bankruptcy Case
Court Appoints Judge Rosen as Mediator in the City of Detroit Chapter 9 Bankruptcy Case
Account Stated and Open Account Actions Involving Sale of Goods Subject to Michigan’s Six-Year Limitations Period
Primary Issues to be Decided in the City of Detroit Chapter 9 Bankruptcy Case
July
City of Detroit Files Chapter 9 Bankruptcy
June
Sixth Circuit Holds Trustee and His Attorneys Protected by Quasi-Judicial Immunity
Michigan Courts May Exercise Jurisdiction Over Businesses that Have Few In-State Contacts
May
Detroit Emergency Manager's Report Declares City "Clearly Insolvent"
April
Release Given by Chapter 11 Debtor Binding on Chapter 7 Trustee
February
Sixth Circuit Recognizes Cause of Action for Aiding and Abetting Tortious Conduct under Michigan Law
Bankruptcy Court Holds 11 U.S.C. § 502(d) Does Not Bar Allowance of an Administrative Claim
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March 04, 2014
Michigan Court of Appeals Refuses to Enforce Contract on Public Policy Grounds
Category:
Practice Updates
March 03, 2014
Michigan Court of Appeals Holds “Outbidding and Outmaneuvering” Does Not Constitute Tortious Interference
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