Advertising Specialty Institute v. Hall-Erickson, Inc.

Dist. Ct. did not err in finding that defendant breached terms of contract giving plaintiff first right of refusal concerning participation in future promotional product/advertising specialties involving defendant, when defendant invited third-party to co-locate trade show with defendant at McCormick Place and failed to offer plaintiff initial opportunity to participate in same trade show. Co-location trade show qualified as covered opportunity as contemplated by contract, and Dist. Ct. could properly reject defendant's argument that third-party's decision to co-locate trade show with defendant was independent act. Moreover, Dist. Ct. did not err in awarding only nominal damages where plaintiff failed to account for diluted demand stemming from participation by plaintiff's members in subject trade show that occurred within four months of another show held by plaintiff, and where plaintiff failed to identify companies that would have attended subject trade show and/or identify actual profits, if any, that third-party generated at subject trade show.