Lost Customer Account: Must Damages Account for Lost Profits, Not Lost Value?

Business Valuation UpdateVol. 15 No. 7
Legal and Court Case Update
July 2009
7371 Computer Programming Services
541511 Custom Computer Programming Services
expert testimony

Netquote v. Byrd (I)
2008 WL 2442049 - Slip Copy
April 29, 2008
Federal Court
United States District Court
Stephen Duree


Court upholds $1.6 million damages award for value of lost customer accounts, rejecting defendants’ argument that, according to applicable law, the proper and exclusive measure of damages is lost future profits.

See Also

Netquote v. Byrd (I)

Court qualifies plaintiff’s expert under Daubert to testify regarding lost value of customer accounts based on review of the accounts, a prior valuation report, and a revenue multiplier derived from existing accounts.