Vexol, S.A. v. Berry Plastics Corp. 

Dist. Ct. did not err in dismissing plaintiff’s claim under Mexican law alleging that defendant aided and abetted others in misleading plaintiff into agreeing to purchase inferior products with intention of stealing plaintiff’s customers, as well as improperly accused plaintiff of fraud, threatened to have plaintiff’s official arrested and instigated false criminal charges in Mexico. Thrust of plaintiff’s complaint was its contention that defendant was directly liable for actions taken by defendant in Mexico, and complaint failed to describe single act that defendant took in Mexico. Moreover, fact that plaintiff alleged that defendant had aided and abetted actions of third-party in committing bad acts did not require different result, since plaintiff failed to provide any authority to suggest that plaintiff’s corporate ownership of third-party was sufficient by itself to establish aiding and abetting liability under Mexican law.