A plaintiff alleging loss of a valuable commercial opportunity must plead: (1) that the loss is a loss of a valuable commercial opportunity, identified with particularity; (2) what the plaintiff would have done if the defendant had not been in breach; (3) the percentage or proportion of the opportunity lost; and (4) where a 100 per cent possibility is alleged, the facts by which that certain outcome would have been achieved. A bare allegation that loss was suffered 'by reason of' breaches of duty is insufficient where the causal connection is not apparent from the facts pleaded.
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