This action involves a dispute over the quality of lighting fixtures installed in the course of renovating premises occupied by defendant Equitable Life. Defendant-appellant Switzer Group, an architectural firm, was the design consultant and defendant-appellant Rose, an architect, was Switzer Group's project executive on the renovation. It is alleged that numerous louvres fell out of the lighting fixtures.
The civil conspiracy causes of action are not cognizable under New York law. (Green v Davies, 182 N.Y. 499, 503; 117 E. 24th St. Assocs. v Karr, 95 A.D.2d 735.)
The libel cause of action, alleging product disparagement, lacks even an allegation of special damages much less proof of such damages as required. (See, Drug Research Corp. v Curtis Publ. Co., 7 N.Y.2d 435; Marlin Fire Arms Co. v Shields, 171 N.Y. 384, 390.)
Concur — Murphy, P.J., Milonas, Ross, Asch and Rubin, JJ.