For the first element, the defendant must intend to cause loss to the plaintiff, either as an end goal or as the means of achieving an end goal, like self-enrichment (Alleslev-Krofchak v. Valcom Ltd., 2010 ONCA 557 at para. 50 [Valcom]). Thus, this element of the tort has been properly pled for the same reasons the plaintiff has properly pled a conspiracy to injure.
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