In the context of a restitution motion, in United States of America v. Dove, the RIAA's "download equals lost sale" theory has been flatly rejected.
In a 16-page opinion, District Judge James P. Jones, sitting in the Western Disrict of Virginia, denied the RIAA's request for restitution, holding the RIAA's reasoning to be unsound:
"It is a basic principle of economics that as price increases, demand decreases. Customers who download music and movies for free would not necessarily spend money to acquire the same product. Like the court in Hudson, I am skeptical that customers would pay $7.22 or $19 for something they got for free. Certainly 100% of the illegal downloads through Elite Torrents did not result in the loss of a sale, but both Lionsgate and RIAA estimate their losses based on this faulty assumption."