Sixth Circuit: Auburn Sales, Inc. v. Cypros Trading & Shipping, Inc.

State tortious interference claim requires the specific intent to interfere with the business relationship.

Even for a requirement or output contract, state statute of frauds requires a writing enforceable against the deft for any claim arising from the transaction.

http://www.opn.ca6.uscourts.gov/opinions.pdf/18a0162p-06.pdf