Correct.  The damages certainly do not arise in the usual course of things.  A mistaken message in a telegram--any telegram--does not, in the normal course of things, give rise to damages resulting from market fluctuations; nor, one might plausibly contend, does this happen in the normal course of things, in the case of telegrams sent by coffee brokers.  The court held, however, that the telegraph company was, or should have been, aware of the special circumstances (what it calls the "business importance" of the message) giving rise to the damages.  The court argued that

We think the reasonable rule . . . is that where a message as written, read in the light of well-known usage in commercial correspondence, reasonably informs the operator that the message is one of business importance, and discloses the transaction so far as is necessary to accomplish the purpose for which it is sent, the company should be held liable for all the direct damages resulting from a negligent failure to transmit it as written, within a reasonable time, unless such negligence is in some way excused. Under this rule, both dispatches as presented to appellant's operator were sufficiently explicit to charge it with the loss sustained by appellees, resulting from what has been found by the jury to be its inexcusable mistakes. Lathrop, 586 -7.

The problem is that, as Judge Cardozo notes in Kerr Steamship Co., Inc. v. Radio Corporation Of America,
245 N.Y. 284 (1927), "{t}he truth seems to be that neither the clerk who receives the message over the counter nor the operator who transmits it nor any other employee gives or is expected to give any thought to the sense of what he is receiving or transmitting. This imparts to the whole doctrine as to the need for notice an air of unreality."  Id. at 291. 

Cardozo offers a policy rationale instead: 

Much may be said in favor of the social policy of a rule whereby the companies have been relieved of liabilities that might otherwise be crushing. The sender can protect himself by insurance in one form or another if the risk of nondelivery or error appears to be too great. The total burden is not heavy since it is distributed among many, and can be proportioned in any instance to the loss likely to ensue. The company, if it takes out insurance for itself, can do no more than guess at the loss to be avoided. To pay for this unknown risk, it will be driven to increase the rates payable by all, though the increase is likely to result in the protection of a few. Id.

Do you find Cardozo's rationale convincing?

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