Commercial Case NotesSpoliation Claim Fails for Lack of Culpable State of Mind By John Lundin November 28, 2023 On November 14, 2023, the First Department issued a decision in National Convention Servs., LLC v. FB Intl., Inc., 2023 NY Slip Op. 05692, holding that a spoliation claim failed for lack of a culpable state of mind, explaining:…