Should tort law protect against a company's loss of productivity due to unsolicited emails? Defendant--a former employee of the plaintiff company--helped form an organization to disseminate information and views critical of plaintiff's employment and personnel policies and practices. As the spokesperson for this organization, the defendant sent six mass emails to as many as 35,000 employees of the plaintiff. There was no evidence that the defendant breached plaintiff's security, nor any evidence that the distribution or receipt of the emails impaired the functioning of plaintiff's computer systems. However, plaintiff argued that its interest in employee productivity had been harmed due to the content of the emails.