The U.S Court of Appeals for the Fifth Circuit reversed a jury's award of lost profits. The court found the award speculative because Dyll did not have a history of successfully producing and marketing technology (HIV detection technology, here).
Louis Dyll, et al. v. Robert Milligan, et al.
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New Business Rule Defeats Lost Profits Award
The U.S Court of Appeals for the 5th Circuit reversed a jury's award of lost profits.