OUJI-CIV No. 28.16

INVASION OF PRIVACY – MEASURE OF DAMAGES

If you decide for Plaintiff [name], you must then fix the amount of

his/her damages. This is the amount of money that will reasonably and

fairly compensate him/her for the injury sustained as a result of the invasion

of privacy by Defendant [name].

In fixing the amount you will award him/her you may consider the

following elements:

1. Financial losses, such as loss of earnings/profits;

2. The harm caused by the intrusion to privacy;

3. Personal humiliation; and

4. Mental anguish and suffering.

OR

1. Financial losses, such as loss of earnings/profits; and

2. The value of the loss of the exclusive use of the

name/voice/signature/photograph/likeness of Plaintiff, [name]);

OR

1. Financial losses, such as loss of earnings/profits;

2. Injury to standing and reputation in the community;

3. Personal humiliation; and

OUJI 3d (Rev. 2009) Chapter 28

4. Mental anguish and suffering.