Pure pecuniary loss, such as medical expenses and lost wages, is another category of injury. It is similar property-loss claims.  Courts have permitted recovery for it in certain IVF cases.  In Paretta v. Medical Offices for Human Reproduction, 760 N.Y.S.2d 639 (Sup. Ct. 2003) the doctor knew that the egg donor had the recessive gene for cystic fibrosis, and skipped a routine test to check if the husband was also a carrier.  When the child was born with the disease, the Parettas successfully sued for the cost of caring for their baby.  The theory of pecuniary loss was futile in the case of the Creeds who did not have a child in the first place.