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They added claims: 1. Tortious Interference with contractual relations 2. Defamation
Tortious Interference with Contractual Relations 56. Enzolytics repeats and realleges the allegations of the foregoing paragraphs as if fully set forth herein. 57. In the context of a claim for tortious interference with contractual relations, a plaintiff must allege facts showing (1) a valid contract, (2) about which the defendants have knowledge, (3) an intentional act by defendants that is a significant factor in causing the breach of the contract, (4) done without justification and (5) which causes injury. 58. Enzolytics and a third-party, Creative Biolabs, had previously entered into a cooperation agreement, whereby the two entities would collaborate in the development of monoclonal antibodies. 59. Savov knew about this cooperation agreement. 60. Savov intentionally contacted Creative Biolabs with the intent to cause Creative Biolabs to cancel the cooperation agreement between Enzolytics and Enzolytics. 61. Specifically, on or about July 20, 2021, Savov, without justification, sent an email to Creative Biolabs stating that Enzolytics was a “hollow company,” stating that “all patents of Harry Zhabilov [one of the founders of Enzolytics]” are the property of IMMB BG and Savov. 62. On July 20, 2021, in response to the correspondence from Savov, Creative Biolabs informed Enzolytics that in order to protect its own company reputation, that it was requesting that Enzolytics suspend any press releases reading the cooperation agreement between Enzolytics and Creative Biolabs until Creative Biolabs could “figure out the situation.” 63. Thereafter, as a direct and proximate result of the statements made by Savov to Creative Biolabs, Creative Biolabs terminated the cooperation agreement with Enzolytics on July 21, 2021. 64. Prior to this incident, Enzolytics and Creative Biolabs had worked together for years. 65. Savov’s actions were done without justification and caused Enzolytics to suffer injury in the form of the cancellation and termination of the cooperation agreement by Creative Biolabs. 66. Upon information and belief, Savov’s conduct is not limited to the relationship between Enzolytics and Creative Biolabs. 67. Upon information and belief, Savov has intentionally interfered and continues to interfere with the contractual relations between Enzolytics and other third-parties. Enzolytics’ investigation is continuing. 68. As a direct and proximate result of Savov’s intentional interference with the contractual relations between Enzolytics and other third-parties, Enzolytics has suffered, and will continue to suffer damages.
DEFAMATION 69. Enzolytics repeats and realleges the allegations of the foregoing paragraphs as if fully set forth herein. 70. The aforementioned statements made by Savov to Creative Biolabs on July 20, 2021 regarding Enzolytics are false. 71. Savov’s false statements refer to Enzolytics. 72. Savov’s false statements were published by Savov to third parties. 73. Savov’s statements are false and defamatory. 74. Savov made such defamatory statements with the knowledge that they were false and/or with reckless disregard for the truth and with the intent to damage Enzolytics. 75. Upon information and belief, Savov has made numerous defamatory statements regarding Enzolytics to third-parties, other than Creative Biolabs. Enzolytics’ investigation is continuing. 76. Savov’s defamatory statements have harmed and continue to harm Enzolytics, causing it to suffer financial loss by way of relationships that have been terminated as a result, including but not limited to the cooperation agreement with Creative Biolabs. 77. Savov’s defamatory statements lowered and continue to lower Enzolytics in the estimation of business associates and potential business associates, and have deterred third parties from associating or dealing with Enzolytics. This was Savov’s intent. 78. As a result of Savov’s defamatory statements, third parties, including, without limitation, business associates and potential business associates have been deterred from associating or doing business with Enzolytics. This was Savov’s intent. 79. As a result of Savov’s defamatory statements, Enzolytics has suffered lost business, money, business associates and potential business associates. This was Savov’s intent. 80. As a direct and proximate result of Savov’s defamatory statements, Enzolytics has suffered, and will continue to suffer damages. This was Savov’s intent.
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