In Conseco Finance Servicing Corp. v. North American Mortgage Co., 381 F.3d 811, 815-16, 825 (8th Cir. 2004), punitive damages were affirmed (albeit reduced) in an unfair competition case involving claims by a business that a competitor had "raided" its employees and encouraged them to bring with them customer leads and confidential information from the plaintiff company. Id. at 820. The court found that punitive damages were appropriate because, inter alia, the defendant company was motivated by a desire to expand its business "at any cost," that management did not investigate or correct the wrongful acts by its employees but instead promoted those acts, and that its actions involved trickery and deceit and demonstrated an "utter disregard" for the competitor and its customers. Id. at 824.