top of page


Proposed Amendment to Prayer for Relief Based on Unrealized Profits Incurred as a Result of Alleged Fraud Violates the Out-Of-Pocket Damages Rule
In Sire Spirits, LLC v. Beam Suntory, Inc., 2025 N.Y. Slip Op. 06297 (1st Dept. Nov. 18, 2025), the Appellate Division, First Department affirmed the denial of a motion to amend a complaint seeking damages for “diminution of enterprise value” due to the alleged fraud.

Jeffrey Haber
Nov 19, 20258 min read
bottom of page
