In Akron-Canton Waste Oil, Inc. v. Safety-Kleen Oil Servs., Inc. (1992), 81 Ohio App. 3d 591, 611 N.E.2d 955, a competitor in the waste oil market was allegedly distributing unfounded police theft reports to Akron-Canton customers which were typically solicited in an impromptu manner.
The court noted that the "common law right of action protects all advantageous business relations, real or potential, from improper interference." Id. at 599.