The House of Lords held that the loss of future orders was not too remote, and that Jackson had an obvious commercial interest in retaining confidential information.
On the issue of remoteness, the judge's assessment was a good one, in that it was increasingly likely as time passed that Economy Bag would want to squeeze Jackson's profit margins.
If for instance (by reference to the facts of Hadley v Baxendale itself) the breach is described simply as a carrier's failure to convey goods from Gloucester and deliver them to Greenwich within two days as promised, it is a matter of speculation what damages would arise naturally and in the ordinary course.
The appropriate characterisation of the breach depends on the terms of the contract, its business context, and the reasonable contemplation of the parties (although Baron Alderson used the latter expression in relation to the second limb).
He referred, at p 356, to the plaintiffs' failure to make known to the defendants: "... the special circumstances, which perhaps, would have made it a reasonable and natural consequence of such breach of contract."
The common ground of the two limbs is what the contract-breaker knew or must be taken to have known, so as to bring the loss within the reasonable contemplation of the parties: see para (4) in the summary by Asquith LJ (giving the judgment of the Court of Appeal) in Victoria Laundry (Windsor) Ltd v Newman Industries Ltd [1949] 2 KB 528, 539.
This seems to me to be consistent with the commonsense approach suggested by Scarman LJ in H Parsons (Livestock) Ltd v Uttley Ingham & Co Ltd [1978] 1 All ER 525 at 541, [1978] QB 791 at 813, and to be applicable here."