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Group Televisa, S.A. v. Telemundo Communications Group, Inc.
United States Court of Appeals for the Eleventh Circuit
485 F.3d 1233 (2011)
Facts
Group Televisa, S.A. (Televisa) (plaintiff) was a Mexican corporation that produced Spanish-language television shows. Telemundo Communications Group, Inc. (Telemundo) (defendant), headquartered in Florida, was Televisa’s main rival in broadcasting Spanish-language soap operas. Juan Mauricio Islas Ilescas (Islas), a Mexican actor, was under an exclusive contract with Televisa for seven years beginning in 2000. Islas’s contract included a Mexican choice-of-law provision. Following a meeting in Mexico and four meetings with Telemundo in Florida, Islas entered into an exclusive contract with Telemundo at Telemundo’s Florida offices in 2003. Most of Telemundo’s written communications with Islas originated from Florida, and Telemundo’s legal counsel researched whether Televisa might have a Florida tort-law claim against Telemundo. Televisa sent a letter to Telemundo informing it of Islas’s exclusive contract with Televisa, and a letter to Islas notifying him that he was expected to be present for the taping of a new show. After Islas failed to appear, Televisa filed suit against Telemundo in Florida federal district court, alleging tortious interference with contract. The district court granted summary judgment to Telemundo, holding that Mexican law applied and did not recognize a cause of action for tortious interference with contract. Televisa appealed.
Rule of Law
Issue
Holding and Reasoning (Fay, J.)
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