Extract to table

If such a price increase would be unprofitable because customers would switch to products outside the proposed market, then the market is too narrowly defined and must be expanded to include the next-closest substitutes

A proper lost-profits damages model must account for the mitigation opportunities available to the plaintiff

The correct "but-for" world must account for the realistic steps Ridgepoint would have taken to mitigate its losses by utilizing alternative infrastructure, and the damages calculation must be reduced by the profits Ridgepoint could have earned through such mitigation

Kuo's model accounts for these factors is unknown and must be explored in discovery

A lost-profits damages calculation must discount projected future profits to present value using an appropriate discount rate that reflects the risk inherent in the projected cash flows

The existence of this holdover arrangement—which provides Ridgepoint with continued, albeit more expensive, access to a portion of Northgate's infrastructure—must be accounted for in any honest damages model and tends to reduce the incremental profits lost as a result of Northgate's alleged conduct