Advent Systems Ltd. v. Unisys Corp

In Advent Systems, Ltd. v. Unisys Corp., 925 F.2d 670 (3d Cir.1991), an expert relied heavily on industry projections prepared in 1986 and 1987. These projections predicted large increases in the sales of document systems. By the time of trial in 1989, however, actual results in the market place did not meet with the sanguine predictions in the market reports. Nevertheless, the expert relied on the projections rather than updating them based on actual results in the market. The Court concluded that "we too have serious reservations about the validity of expert testimony based on prior predictions of sales for a given period when actual performance data for that same time span are available." Id. at 682. In Advent Systems Ltd. v. Unisys Corp., 925 F.2d 670 (3d Cir.1991) the Court followed the reasoning of Green v. Interstate United Management Serv. Corp., 748 F.2d 827, 831 (3d Cir.1984) in a prospective contractual relations case where the parent pressured its subsidiary to terminate contract negotiations. The Court reasoned that the parent's "interest in the financial stability of its subsidiary and the need to avoid a situation where the two would be working at cross-purposes justified the disruption of negotiations with plaintiff." Id. at 673.