McAlister v. Loeb

Summary

The court held that plaintiffs could not recover lost profits from prospective licensing transactions because they failed to show that the parties had agreed on material terms such that the transactions were reasonably certain to occur, and the claimed profits were therefore speculative. Because lost profits were the only damages sought, the trespass-to-chattel claim also failed without the court deciding whether electronic interference with patent applications can constitute trespass to chattel. The court affirmed summary judgment on those claims and remanded the remaining slander-of-title claim for further proceedings.