In Stevenson Real Estate Servs., Inc. v. CB Richard Ellis Real Estate Servs., Inc., ___ Cal.App.4th ___ (Apr. 26, 2006), the complaint attempted to plead a cause of action for intentional interference with prospective economic advantage, using an alleged UCL violation as the "independently wrongful act" required to plead that cause of action under Korea Supply Co. v. Lockheed Martin Corp., 29 Cal.4th 1134 (2003). Slip op. at 3-4. To count as an "independently wrongful act," the conduct must be "proscribed by some constitutional, statutory, regulatory, common law, or other determinable legal standard.” Id. at 5 (citing Korea Supply, 29 Cal.4th at 1159). The Court of Appeal (Second Appellate District, Division Eight) held that the trial court properly granted judgment on the pleadings because the complaint did not adequately allege a violation of the UCL's "unfair" prong as interpreted in Cel-Tech Communications, Inc. v. Los Angeles Cellular Tel. Co., 20 Cal.4th 163, 187 (1999), which governs competitor actions. Slip op. at 10-11. The opinion seems to assume that the "fraudulent" prong does not apply to competitor actions. See id. at 11 n.4. Nor was the "unlawful" prong mentioned — presumably because if the plaintiff could have alleged some other violation of law, it would not have needed to rely on the UCL to state a claim for intentional interference with prospective economic advantage.