What is the test for establishing a cause of action for interference with economic interests?

Plaintiffs' first cause of action is predicated on the doctrine of civil conspiracy. We keep in mind, of course, that the real gist of such an action is not the conspiracy itself, but rather the damages suffered thereby: "It is the long established rule that a conspiracy, in and of itself, however atrocious, does not give rise to a cause of action unless a civil wrong has been committed resulting in damage. (Citations)" (Wise v. Southern Pacific Company (1963) 223 Cal.App.2d 50, 64, 35 Cal.Rptr. 652, 660.) Hence, to state an action for conspiracy, the complaint must allege (1) its formation and operation, (2) wrongful acts done pursuant thereto and (3) damages arising therefrom. (Id., p. 64, 35 Cal.Rptr. 652.)

Accordingly, the real substance of plaintiffs' complaint is the injury suffered as a result of defendants' intentional interference with their plaintiffs prospective economic advantage. "This is a tort theory of recovery . . . based on interference with a 'relationship' between parties irrespective of the enforceability of the underlying agreement. . . . The actionable wrong lies in the inducement to break the contract or to sever the relationship . . .." (Buckaloo v. Johnson (1975) 14 Cal.3d 815, 822, 122 Cal.Rptr. 745, 748, 537 P.2d 865, 868.) This cause of action requires five essential components: (1) an economic relationship containing the probability

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