California, United States of America
The following excerpt is from Macken v. Martinez, 214 Cal.App.2d 784, 29 Cal.Rptr. 867 (Cal. App. 1963):
As said in Zinn v. Ex-Cell-O Corp. (1944) 24 Cal.2d 290, 149 P.2d 177, 'One whose wrongful conduct has rendered difficult the ascertainment of the damages cannot escape liability because the damages could not be measured with exactness.' (pp. 297-298, 149 P.2d p. 181.)
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