(Punctuation omitted.) McCannon v. McCannon, 231 Ga. App. 601(1) ( 499 S.E.2d 684) (1998). When a seller has breached its warranty, a buyer may recover the difference between the price paid for the goods and the value of the goods delivered.

Here, there was some evidence providing the jury with a basis to determine the amount of Church's damages, and thus the trial court did not err in denying the Caldwell's motion for JNOV and directed verdict. See Rafferzeder v. Zellner , 272 Ga. App. 728, 613 S.E.2d 229 (2005) (questions of value are peculiarly for determination of fact finder where there is any data upon which fact finder may exercise its own knowledge and ideas); McCannon v. McCannon , 231 Ga. App. 601 (1), 499 S.E.2d 684 (1998) ("In evaluating the sufficiency of evidence regarding damages, the ability to estimate damages to a reasonable certainty is all that is required and mere difficulty in fixing the exact amount will not be an obstacle to the award. The rule against the recovery of vague, speculative, or uncertain damages relates more especially to the uncertainty as to cause, rather than uncertainty as to the measure or extent of the damages.") (citation and punctuation omitted).

(Citation and punctuation omitted.) McCannon v. McCannon, 231 Ga. App. 601 (1) ( 499 S.E.2d 684) (1998). So viewed, the evidence shows that Hill Roofing opened a business charge account at Lowe's on October 29, 1997.

(Citations and punctuation omitted.) McCannon v. McCannon, 231 Ga. App. 601 (1) ( 499 S.E.2d 684) (1998). An action for conversion may lie for the cutting and removal of trees. "The tort of conversion involves an unauthorized assumption and exercise of the right of ownership over personal property belonging to another, in hostility to his rights; an act of dominion over the personal property of another inconsistent with his rights; or an unauthorized appropriation.

The any evidence standard of review for the denial of the motion for directed verdict requires the affirmance of the trial court. McCannon v. McCannon, 231 Ga. App. 601 (1) ( 499 S.E.2d 684) (1998); Doubletree, Inc. v. Schanley, 226 Ga. App. 776 ( 487 S.E.2d 506) (1997). 5. Plaintiffs contend that the trial court erred in admitting speculative and incompetent evidence of defendants' damages and lost profits.

(Punctuation omitted.) McCannon v. McCannon, 231 Ga. App. 601(1) ( 499 S.E.2d 684) (1998). Prior to the enactment of the GCPT in 1973, Georgia recognized that a railroad could be negligent for the failure to install protective devices at grade crossings on public roads.

The factfinder, that is, "cannot be left to speculation, conjecture and guesswork." Id.; see also, e.g., McCannon v. McCannon, 499 S.E.2d 684, 686 (Ga. Ct. App. 1998) (damages must be proved "to a reasonable certainty"); Restatement (Second) of Contracts § 352 (1981) ("Damages are not recoverable for loss beyond an amount that the evidence permits to be established with reasonable certainty."). In this lawsuit, LNV thus had the burden of proving a "reasonabl[y] certain[]" estimation of its expectation interest—or whatever benefit its bargain with BB&T warranted. As we explain below, we agree with the district court that LNV failed to prove this essential cornerstone.

Plaintiffs' amended allegations estimate their damages to a reasonable degree of certainty. SeePendley Quality Trailer Supply, Inc. v. B&F Plastics, Inc. , 260 Ga.App. 125, 578 S.E.2d 915, 919 (2003) (noting that "the ability to estimate damages to a reasonable certainty is all that is required and mere difficulty in fixing the exact amount will not be an obstacle to the award" (citing McCannon v. McCannon , 231 Ga.App. 601, 499 S.E.2d 684, 686 (1998) )); see alsoHawthorne Indus., Inc. v. Balfour Maclaine Int'l, Ltd. , 676 F.2d 1385, 1387–88 (11th Cir. 1982) (noting that reasonable certainty is all that is required). Accordingly, dismissal on this basis is not warranted.

The rule against the recovery of vague, speculative, or uncertain damages relates more especially to the uncertainty as to cause, rather than uncertainty as to the measure or extent of the damages." Pendley QualityTrailer Supply, Inc. v. B&F Plastics, Inc., 578 S.E.2d 915, 919 (Ga. Ct. App. 2003) (quoting McCannon v. McCannon, 499 S.E.2d 684, 686 (Ga. Ct. App. 1998)). As such, "[e]vidence that the [chippers] were defective cannot alone establish the value of the[m] as accepted," and the determination of the measure of damages "cannot be left to speculation, conjecture and guesswork."