The District Court decided that the proper measure of damages was the "reasonable royalty" that the infringing party would have paid for American Sales' customer list had it paid for authorization to use the list. American sold discount packages to consumers through an MLM sales model. Adventure Travel was a one-time supplier of discounted travel to American Sales members. Adventure subsequently formed a similar competing MLM company and used the list that American had provided under the terms of a previous contract. The Court held that the value of the list to Adventure should be the amount of damages paid to American.

The case is also available at: http://www.mlmlegal.com/legal-cases/American-Sales-Corp_v_Adventure-Travel.php.