In Security Stove & Mfg. Co. v. American Ry. Express
Co. 227 Mo.App. 175, 51 S.W.2d 572 (Mo.App. 1932), Security Stove wanteda
stove shipped in 22 packages from Missouri to New Jersey for an
exhibition.They hoped to get a
distributor interested in their product. They actually wrote to the president
of the shipping company (meeting the Hadley v. Baxendale standard!) Only 21 packages arrived.Since the show was just an exhibition,
there was no real loss of profit, but there was considerable loss of goodwill
and potential future profits.Court found (and Appellate Court agreed) that costs associated with the
exhibition (such as the price for the exhibition booth, travel expenses, and
employee's time) was recoverable, including those expenses prior to the
contract!This is contrary to the Chicago
Coliseum v. Dempsey decision.This case is a good example of reliance
interest and loss of goodwill.