Eliza opened a new book store. It had been open only two months when there was a fire that destroyed the building and all Eliza's inventory.$$ Eliza sued the commercial landlord, who was found to be responsible for the fire.

Eliza did not have reliable budgets or forecasts.$$ The first two months were not profitable, because of a lot of non$-$recurring start up expenses..$$

Which approach would be most appropriate to determine his lost profits?

Yardstick or benchmark approaches comparing Eliza's store to other businesses just like hers.

A "before and after" approach relying on the two start$-$up months' data.

Eliza's damages can not be calculated because there is no way to establish damages with insufficient sales and cost history.

A disgorgement approach based on the landlord's profits.