Stevens Linen Associates, Inc. v. Mastercraft Corp.
United States Court of Appeals for the Second Circuit
656 F.2d 11 (1981)
Stevens Linen Associates, Inc. (plaintiff) created and copyrighted a fabric design called Chestertown in 1976; competitor Mastercraft Corporation (defendant) saw the design on display and created two fabrics based on it. After the district court found copyright infringement, the parties litigated damages, and Stevens advanced several theories for lost sales: Mastercraft's total sales of the infringing fabrics, Stevens's own pre-infringement sales projections for Chestertown, and lost sales to customers who had bought both Chestertown and the infringing fabrics. The district court rejected all of Stevens's theories as too speculative, and Stevens appealed.
Whether some degree of speculation is permissible in calculating a copyright plaintiff's compensatory damages for lost sales, and what evidentiary support such damages require.