On March 28, 2023, Justice Crane of the New York County Commercial Division issued a decision in NW Media Holdings Corp. v. IBT Media Inc., 2023 NY Slip Op. 30966(U), dismissing a conspiracy claim as duplicative of an aiding and abetting claim, explaining:
However, the court grants Uzac’s motion to dismiss the cause of action for conspiracy as to conversion. A claim for conspiracy is subject to dismissal where it is duplicative of an aiding and abetting cause of action. Here, the aiding and abetting allegations against Uzac are essentially the same as the conspiracy allegations against Uzac.
(Internal citations omitted).