The U.S. District Court for the District of Columbia dismissed a claim for tortious interference with business relationships where the complaint accused the defendant of tortiously interfering with the very same contract the defendant was accused of breaching.

In early 2009, Geoplast S.p.A., an Italian plastics manufacturer, contracted with I Mark Marketing Services, LLC (IMARK), a U.S. marketing firm, to operate a U.S. Geoplast subsidiary and market Geoplast’s products. Among other things, the original contract granted IMARK exclusive marketing rights to Geoplast’s products in the United States.