I. [§ 3.204] Civil Conspiracy

• Jurisdiction: Maryland

I. [§ 3.204] CIVIL CONSPIRACY

Computer Software Systems is a manufacturer and distributor of a computer software package known as the "C.S. System." In August 2021, without the consent or knowledge of Computer Software Systems, John Smith, a former employee of Computer Software Systems, and George Harris, a computer software expert, developed and operated a computer software duplication service. During the next six months, Smith and Harris copied and sold more than 1,000 duplicates of the C.S. System. In May 2022, Computer Software Systems discovered that pirated C.S. System programs were being sold by Harris and Smith. As a result, Computer Software Systems brought this action for civil conspiracy.

COMPLAINT

Civil Conspiracy

Computer Software Systems, Inc. (hereinafter "CSS"), Plaintiff, by its attorneys, James P. Callahan and Callahan & Callahan, P.A., sues John Smith (hereinafter "Smith") and George Harris (hereinafter "Harris"), Defendants, and states:
1. Plaintiff CSS is a Maryland corporation duly organized under the laws of Maryland with its principal place of business in Baltimore County, Maryland.
2. Defendant Smith is a resident of Baltimore County, Maryland.
3. Defendant Harris is a resident of Baltimore County, Maryland.
4. CSS is a manufacturer and distributor of computer software programs. Since January 2017, CSS has been the exclusive manufacturer and distributor of a computer software package known as
the "C.S. System."
5. Without the consent or approval of CSS, on or about August 1, 2021, Defendant Smith, a former employee of CSS, entered into an agreement with Defendant Harris, a computer software expert, whereby Smith and Harris agreed to wrongfully reproduce, manufacture, and sell the C.S. System. Under the terms of the agreement, Smith agreed to provide the design specifications for the C.S. System and Harris agreed to reproduce the C.S. System.
6. Without the consent or approval of CSS, on or about August 1, 2021, Defendant Smith unlawfully provided the design specifications for the C.S. System to Defendant Harris, and Defendant Harris unlawfully duplicated the C.S. System.
7. On or about August 2, 2021, Defendant Smith and Defendant Harris unlawfully sold and distributed unauthorized duplications of the C.S. System. During the following six months, Defendants unlawfully sold and distributed more than One Thousand (1,000) duplicates of the C.S. System.
8. As a result of Defendants Harris's and Smith's conspiracy to reproduce, manufacture and sell the C.S. System, CSS has suffered severe economic injury, including lost sales, lost profits and other compensatory damages totaling more than One Hundred Thousand Dollars ($100,000).
WHEREFORE, Computer Software Systems, Inc. demands judgment against Defendants John Smith and George Harris, jointly and severally, in excess of Seventy-Five Thousand Dollars ($75,000) in compensatory damages, plus interest and costs.

__________
James P. Callahan
AIS No. 0123456789
Callahan & Callahan, P.A.
Exelon Building
1310 Point Street
Baltimore, Maryland 21231
Phone: (410) 555-1234
Fax: (410) 555-1235
Email: JCallahan@CallahanLaw.com

Attorneys for Plaintiff

COMMENT

The elements of an action for civil conspiracy are:

1) A confederation of two or more persons by agreement or understanding;
2) Some unlawful or tortious act done in furtherance of the conspiracy or use of unlawful or tortious means to accomplish an act not in itself illegal; and
3) Actual legal damage resulting to

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