## Facts

- Grupo Televisa, S.A. and related Mexican entities produced Spanish-language programming and used talent under exclusive services agreements.
- Juan Mauricio Islas Ilescas, a Mexican actor, entered a seven-year exclusive services contract with Televisa beginning in 2000.
- The Televisa–Islas contract was governed by Mexican law under an express choice-of-law clause, and performance of Islas’s services was centered in Mexico.
- Telemundo Communications Group, Inc. and related entities, headquartered in Florida, competed with Televisa in Spanish-language television programming.
- In 2003, Islas met with Telemundo representatives in Mexico and attended several meetings in Florida.
- Islas ultimately signed an exclusive contract with Telemundo at Telemundo’s Florida offices, after communications and negotiations largely originating from Florida.
- Televisa notified Telemundo of Islas’s existing exclusivity obligations and directed Islas to appear for production; Islas failed to appear.
- Televisa sued Telemundo in the Southern District of Florida, asserting a Florida-law claim for tortious interference with contract.

## Issues

1. Under Florida’s “most significant relationship” test for tort choice of law, whether Mexican or Florida law governed Televisa’s tortious-interference claim arising from alleged interference with a Mexican actor’s exclusive services contract.

## Decision

- The district court converted Telemundo’s Rule 12(b)(6) motion into one for summary judgment and held Mexican law governed under Florida choice-of-law rules.
- Because Mexican law did not recognize a cause of action for tortious interference as pleaded, the district court entered summary judgment for Telemundo.
- The Eleventh Circuit affirmed, holding Mexico had the most significant relationship to the parties and the occurrence and thus supplied the governing substantive law.
- The court rejected Televisa’s argument that Florida law applied merely because much of the alleged interfering conduct occurred in Florida.

## Legal Principles

- A federal court sitting in diversity applies the forum state’s choice-of-law rules.
- Florida applies the Restatement-based “most significant relationship” test to tort claims, considering: (1) place of injury, (2) place of conduct causing injury, (3) parties’ domicile/nationality/place of business, and (4) where the parties’ relationship is centered.
- For a tortious-interference claim tied to an underlying contract, the jurisdiction governing and centering that contract—including an express contractual choice-of-law clause—may strongly influence the “most significant relationship” analysis.
- If the chosen governing law does not recognize the asserted tort claim, the claim fails as a matter of substantive law, supporting summary judgment.

## Conclusion

The Eleventh Circuit applied Florida’s “most significant relationship” approach and concluded Mexico’s connections—Mexican parties and performer, Mexico-centered performance, and a Mexican choice-of-law clause in the underlying contract—outweighed Florida’s conduct-related contacts, requiring application of Mexican law and defeating Televisa’s tortious-interference claim.


Grupo Televisa, S.A. v. Telemundo Commc'ns Grp., Inc., 485 F.3d 1233 (11th Cir. 2007)