Holly Moose & Associates v. U.S. Legal Support, In
In this action for unfair competition, the trial court determined that plaintiff Holly Moose had failed to prove unfair competition (Bus. & Prof. Code, § 17200 et seq.) in her action against defendant U.S. Legal Support, Inc. (U.S. Legal), a foreign corporation doing business in California using certified shorthand reporters as independent contractors. The trial court first ruled that U.S. Legal was not required to comply with the Moscone-Knox Professional Corporation Act (Moscone-Knox Act or the Act) because it was not itself practicing shorthand reporting. The court further found that plaintiff had failed to show economic injury. Although we find error in the court’s reasoning on both elements of plaintiff’s cause of action, we nonetheless uphold its ultimate conclusion that plaintiff was unable to support her claim of economic injury caused by U.S. Legal’s conduct in this state. Accordingly, we must affirm the judgment.
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