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A defendant negligently caused a small fire in a restaurant kitchen. The owner proves $40,000 in repair costs and two weeks of lost profits based on detailed prior sales records. The owner also claims $500,000 for a possible franchise expansion that an investor had only discussed informally. Which damages ruling is most accurate?

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Lost profits are never recoverable in tort. Repair costs are unavailable if any lost profits are awarded. The proven repair costs and reasonably certain lost profits may be recoverable, but speculative expansion profits should be denied. All claimed losses are recoverable because any business loss after a tort is compensable.

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