Advertising Specialty Institute v. Hall-Erickson, Inc.

ASI (plaintiff), a trade publisher for the promotional products industry, had a contract giving it a right of first refusal to participate in Hall-Erickson's (defendant) annual Chicago trade show. Hall-Erickson breached by inviting ASI's direct rival, PPAI, to co-locate at its 2003 show instead of offering ASI the spot. At trial, ASI's expert estimated lost revenue of $500,000 to over $1,000,000, but ASI never addressed how running two Chicago shows in one year might affect its own attendance, never identified which companies would likely have attended a second ASI show, and never obtained data on PPAI's actual show revenues or attendees. The trial court found breach but awarded only nominal damages of $1 for failure to prove damages with reasonable certainty.