Plaintiff established that the NFL and the Baltimore Ravens had infirnged his copyright in a drawing for the Balitmore Ravens logo.  He claimed damages based on a variety of sources of revenue to the team, including merchandise sales and broadcast income.  The Fourth Circuit holds that there must be a conceivable connection between the infringement and the revenue, and a more than speculative causal link.

Bouchat v. Baltimore Ravens, No. 02-1999 (4th Cir. Oct. 8, 2003).