Damages
Damages computation
Claimed
Calculated
Documented
Items
1 documented · 5 not · 2 approved · 1 disclosure ready
| ID | Category | Theory | Counts | Claimed | Calculated | Inputs | Documents | Status |
|---|---|---|---|---|---|---|---|---|
| DMG-001 | Lost revenue | Unpaid 30% revenue share on license fees Halvorsen collected but did not report in 2025. | 1, 4, 6 | $577,500.00 | $577,500.00 | 3 | 3 | DocumentedApprovedDisclosure ready |
| DMG-002 | Interest | Prejudgment interest on each unpaid quarterly share from its due date. | 1 | — | Cannot calculate | 2 | 0 | Undocumented |
| DMG-003 | Lost business | Lost profits on the Northstar and Calloway relationships. | 3, 5 | — | Cannot calculate | 4 | 3 | UndocumentedExpert |
| DMG-004 | Other | Reasonable royalty for Rennick’s use of Tempo’s models (DTSA alternative measure). | 2 | — | Cannot calculate | 1 | 2 | UndocumentedExpert |
| DMG-005 | Other | Disgorgement of the $612,000 transferred from Halvorsen to Rennick. | 6 | $612,000.00 | Cannot calculate | 1 | 1 | UndocumentedApproved |
| DMG-006 | Legal expenses | Audit costs under § 7.3 and attorney’s fees under 18 U.S.C. § 1836(b)(3)(D). | 1, 2 | — | Cannot calculate | 0 | 1 | Undocumented |
Claimed, Calculated, Documented.Three Totals, Never Added Together.
What counsel claims, what the formulas work out to over their inputs, and the part of that resting entirely on documents. An item whose formula cannot be worked out is left out of the calculated total, not guessed at.
Claimed
Calculated
Documented
Items
1 documented · 5 not · 2 approved · 1 disclosure ready
Every Input Traced.The Formula, the Inputs, the Documents.
Each item shows its formula, its working, and every input with the document it comes from and the assumptions behind it. Attorney approval and disclosure readiness are marked on the item.
← Damages
DMG-001 — Lost revenue
Unpaid 30% revenue share on license fees Halvorsen collected but did not report in 2025.
Calculation
Every input is tied to the document it comes from.
(confirmed − reported) × share
($3,140,000 confirmed − $1,215,000 reported) × 30% = $577,500
| Input | Value | Source |
|---|---|---|
| License fees confirmed by customers | $3,140,000 | MERIDIAN-000013Customer license confirmations (compiled) |
| License fees reported by HalvorsenSum of the four quarterly reports. | $1,215,000 | MERIDIAN-000014License fee reconciliation — 2025 (workbook) |
| Revenue share§ 4.2 | 30% | MERIDIAN-000001Reseller and Implementation Agreement |
Assumptions. Customer confirmations are complete for 2025. The Q4 'consulting' invoices are license fees under § 4.2's 'however described' language.
Calculated damages
$577,500.00
Supports Counts 1, 4, 6.
Undocumented, Not Estimated.No Figure Without Its Basis.
An input with no source document is marked, and the item stays undocumented until it has one. Items that need an expert say so.
The module will not display a figure that has neither a computation nor the material it rests on.
DMG-003 — Lost business
Lost profits on the Northstar and Calloway relationships.
Σ ACV × margin × annuity(12%, years)
| Northstar annual license | $840,000 | MERIDIAN-000006 |
| Calloway annual license | $415,000 | MERIDIAN-000006 |
| Contribution marginFrom client finance; document not yet collected. | 72% | No source |
| Discount ratePlaceholder pending expert. | 12% | No source |
Needs a damages expert. Ito does forensic accounting, not lost profits.
Proposed From the Pleading.Every Claimed Category Accounted For.
An agent reads the claimed damages and the case documents and proposes items not yet recorded, each with its inputs and their sources. A claimed category with nothing documenting it is proposed as undocumented damage.
Propose damages computations
From the pleading’s claimed damages and the documents in the case, propose damages items not already recorded, each with its inputs and the document each input comes from.
Exemplary damages under the DTSA, 18 U.S.C. § 1836(b)(3)(C)
Claimed in the prayer for relief. Nothing in the case documents a computation for it yet, so it is proposed as undocumented damage rather than given a figure.