In Heil-Quaker Corp. v. Mischer Corp., 863 S.W.2d 210 (Tex. App.--Houston 14th Dist. 1993), writ granted, judgm't vacated w.r.m., 877 S.W.2d 300 (Tex. 1994), the appellants argued there was no evidence to support the jury finding of tortious interference with business relations because the tortious interference alleged was directed to an existing contract rather than a prospective contractual relationship. Id. at 214.
The court rejected this contention, stating that tortious interference with business or prospective contractual relations concerns not only business relations that have not yet been reduced to a contract but also continuing business relations not amounting to a formal contract. Id. (citing RESTATEMENT OF TORTS (SECOND) § 766B, cmt. a, c (1979)).