MEMORANDUM DECISION AND ORDER I. INTRODUCTION Plaintiff David Harris commenced this action on September 8, 2020, alleging a claim of unfair competition under New York’s common law against Defendants Matthew Edge, Bridget Stromberg, and Lisa De Simone (hereinafter “the Defendant Authors”) and the American Accounting Association (hereinafter “Defendant AAA”). See Dkt. No. 1. In March 2021, the Defendant Authors and Defendant AAA each separately moved to dismiss the complaint. See Dkt. Nos. 34, 35. In response, Plaintiff filed an amended complaint, see Dkt. No. 37, as well as responses to Defendants’ motions, see Dkt. Nos. 38, 39. The Court thereafter issued a text order permitting Defendants to supplement their pending motions, see Dkt. No. 42, which Defendants did, see Dkt. Nos. 43, 44. While Defendants’ motions were pending, Plaintiff filed a letter motion requesting permission to file a motion for sanctions. See Dkt. No. 49. The Court denied Plaintiff’s request in a text order. See Dkt. No. 54. Currently before the Court are Defendants’ respective motions to dismiss the amended complaint. For the reasons that follow, Defendants’ motions to dismiss the amended complaint are granted and Defendants are awarded costs and reasonable attorney’s fees. II. BACKGROUND1 Plaintiff is a professor at Syracuse University and resides in the State of New York. See Dkt. No. 37 at 9. According to the amended complaint, in 2007, Plaintiff and several other professors “unofficially published a working paper” on the website of nonparty SSRN,2 id. at 143, “on the topic of how a firm employing its auditor for non-audit tax consulting services affected the quality of the firm’s financial statements,” id. at 117. The paper was updated in 2008. See id. at 120. Plaintiff claims that this paper asserted two unique and novel hypotheses; namely, that (1) “[t]here is no association between auditor tax consulting and the likelihood of tax-related [internal control weaknesses ('ICWs')]“; and (2) “[t]here is no association between auditor tax consulting and the likelihood of non-tax-related ICWs.” Id. at
121, 126. Plaintiff’s paper ultimately found that auditor tax consulting was significantly associated with a reduced likelihood of receiving any type of ICW. See id. at 129 The amended complaint next asserts that, in January 2012, the Defendant Authors submitted a paper to Defendant AAA for a presentation at Defendant AAA’s upcoming national meeting. See id. at 163. At this time, the Defendant Authors appear to have been serving as either teaching assistants or research assistants at the University of Texas at Austin. The January 2012 paper asserted a hypothesis and result identical to Plaintiff’s first hypothesis and result, but did not cite or make reference to Plaintiff’s paper. See id. at 163, 181. The Defendant Authors’ January 2012 paper did cite to an unrelated research paper published in 2011 that, in turn, cited to Plaintiff’s paper. See id. at
