Plaintiffs allegations that, upon information belief, they "lost multiple clients based on the series of websites published by the Pacellis and John Does" and that they "have had to pay expenses to protect their reputation, including an online reputation management and monitoring company and attorneys" are insufficient to plead the special damages element of the cause of action.
Cedeno v. Pacelli, NY Slip Op 01552 (1st Dep't March 18, 2021)
