Generally, the law does not recognize IVF plaintiffs’ procreative interest.  Therefore, IVF plaintiffs cannot recover for procreative injury, no matter how serious the injury is.  There are no existing legal theories in tort law that includes the losses attached with this new technology.  Similarly, there is no uniform law governing legal theories for aggrieved IVF patients, apart from some state laws for their protection.  However, there have been instances where courts have gone beyond the general law and have allowed a claim.  Generally, litigation relating to IVF occur on grounds emotional distress, physical injury, loss of property, pecuniary loss and breach of contract.