Westside Center Associates v. Safeway Stores 23, Inc. (1996) 42 Cal.App.4th 507 examined many cases in connection with the claim before it, which was that liability could be imposed for interfering with prospective relationships with "as yet unidentified" third parties. (Id. at p. 520.) Examining various cases, the court agreed with the view that "a defendant's tortious conduct must have interfered with a specific existing relationship, not simply with the formation of one in the future" (id. at p. 525), and found that view gained additional support from the usual formulation of the elements of the tort itself: "These requirements presuppose the relationship existed at the time of the defendant's allegedly tortious acts lest liability be imposed for actually and intentionally disrupting a relationship which has yet to arise" (id. at p. 526).