Extract to table

Under well-established New York law, lost profits must be proven with "reasonable certainty" and cannot be merely speculative, possible, or imaginary

While mathematical precision is not required, the plaintiff must present a damages model grounded in reliable data and reasonable assumptions that permit the factfinder to determine damages without resorting to conjecture

5% EBITDA margin, she must justify the higher figure with project-level cost data demonstrating that the Northgate contract was more profitable than Meridian's business as a whole

Conversely, if she uses a lower project-specific margin, the basis for that figure must also be documented and defensible

Conversely, if the lost-profits figure is calculated net of the convenience fee, the two components may not overlap — but in that case, the lost-profits figure must be reduced accordingly, and the methodology for the netting must be transparent and defensible

Forster must account for Meridian's duty to mitigate in her damages model, and her failure to do so would constitute a methodological deficiency