Some courts have allowed business owners to recover when the alleged injuries occurred on water as a result of activities that occurred on land. See: Masonite Corp. v. Steede, 198 Miss. 530, 23 So. 2d 756 (Miss. 1945) (concluding that a business owner could recover a judgment against a manufacturing plant for loss of profits she claimed she would have made in her business but for the plant's discharge that killed the fish in the Pascagoula River); Hampton v. North Carolina Pulp Co., 223 N.C. 535, 27 S.E.2d 538 (N.C. 1943) (holding that a fishery owner had stated a cause of action for nuisance because the waste from a pulp mill had destroyed or diverted the run of the fish, which seriously injured or destroyed his business and diminished the value of his riparian property).