The damages sought in a non-compete setting are often the lost profits of the plaintiff due to the allegedly improper actions of the defendant. Williamson v. Palmer, 199 Ga. App. 35, 404 S.E.2d 131 (1991)(Breach of a covenant not to compete gives rise to damages for lost profits, measured by plaintiff’s losses, among other damages); Annis v. Tomberlin, 195 Ga. App. 27, 392 S.E.2d 717 (1990). Georgia law is clear that, as with any damages, lost profits must be proven with “reasonable certainty.” Williamson, 404 S.E.2d at 133 (plaintiff must be able to estimate damages to a degree of “reasonable certainty” and difficulty fixing exact amount does not bar award); See also, Premier/Georgia Management Company, Inc. v. Realty Management Corporation, 272 Ga. App. 780, 613 S.E.2d 112 (2005); Boleta v. World Championship Wresting, Inc., 271 Ga. App. 555, 610 S.E.2d 92 (2005); Annis 392 S.E.2d at 722 (”A party who has been injured by a breach of contract can recover profits that would have resulted from performance, when their amount and the fact that they have been prevented by the breach of the [party] can be proved with reasonable certainty”); Fidelity National v. Wood, 375 S.B.2d 228 (1988); Radlo of Georgia v. Little, 199 S.E.2d 835 (1973).

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