Printed Image of York, Inc. v. Mifflin Press, Ltd., 133 A.3d 55

Contract dated July 25, 2006: Appellant sold assets to Appellees and received an initial $1,500 at closing.
Commission payments were to be paid over three years as a percentage of monthly gross sales, with a declining rate (10%, then 7.5%, then 5%).
Appellees allegedly made four commission payments totaling $2,675. (last in January 2007)
At trial, Appellees’ witness testified to the four payments, while Appellant argued the redacted documentation prevented proper damages calculation.
Trial court granted a nonsuit in September 2014 for lack of proven damages, then entered judgment in favor of Appellees in March 2015 after post-trial briefing.
On appeal, the court held the first issue moot and affirmed the nonsuit based on damages proving requirements, including lack of identifiable, non-speculative damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction over post-trial relief	Appellant contends court lacked jurisdiction due to 120-day disposal failure	Court rulings and Rule 227.4 do not require remand; judgment timely under Rule 227.4	Moot; no practical effect from remand
Sufficiency of damages proof for breach of contract	Appellant presented Exhibit 4 and prior-year sales for damages	Damages were speculative; overlapping customers unknown; Exhibit 4 unreliable	Nonsuit proper; damages not proven with reasonable certainty

Gillard v. Martin, 13 A.3d 482 (Pa. Super. 2010) (nonsuit standard; damages proof required for relief)
Newman Dev. Grp. of Pottstown, LLC v. Genuardi’s Family Mkt., Inc., 98 A.3d 645 (Pa. Super. 2014) (damages must be proven with certainty)
Logan v. Mirror Printing Co. of Altoona, 600 A.2d 225 (Pa. Super. 1991) (damages must be proven with reasonable certainty)
Spang & Co. v. U.S. Steel Corp., 545 A.2d 861 (Pa. 1988) (damages too speculative not recoverable)
Billig v. Skvarla, 853 A.2d 1042 (Pa. Super. 2004) (appeal from judgment on post-trial motion timing)