11th Circuit excludes expert accountant’s lost profits testimony

This Eleventh Circuit decision affirmed the trial court’s exclusion of an accountant’s testimony on lost profits, which is a common way in which business plaintiff’s attempt to prove economic damages. In this particular case, the accountant’s estimates were based gross sales and gross profits without any deduction for expenses (one wonders how he could have testified as to profits without deducting expenses?). At any rate, the trial court and the 11th Circuit ruled that the accountant’s opinion was inconsistent with the law of lost profits under applicable Georgia law and that it relied on methods not generally accepted in the accounting community. Interestingly, the 11th Circuit upheld the trial court’s exclusion of the testimony even though the defendant’s Daubert objection was not raised until trial. Waiting until trial to raise a Daubert objection is risky and generally not a recommended strategy.

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