M & A Technology, Inc. v. iValue Group, Inc. rejected a claim for lost business value arising from the destruction of a business, an issue which intersects lost profits projection and business valuation. Plaintiff disclaimed recovery of lost profits damages at trial. The court held, however, that use of a business valuation approach (which the court analyzed in detail) could not remedy deficiencies in proof of value by methodology dependent on income projection. This case is perhaps the first to explore the relation between damages derived by business valuation and damages derived by lost profits projection. The court correctly concluded that a business valuation based on speculative income projections is subject to the same objections that the income projections would be if a lost profits analysis were done. River Bridge Corp. v. American Somax Ventures considered what was necessary to prove lost profits damages by a “yardstick” approach, developing a lost profits analysis by comparison to data derived from others in the same business. The court found the “yardstick” not to be comparable and rejected plaintiff’s proof.