Is Holdover Rent of 200% of Base Rent a Valid Liquid Damages Provision?

What Happened: After siding with the landlord on all claims, a New York court had one more issue to decide, namely, whether the lease clause requiring the tenant to pay 200 percent of base rent as holdover rent was enforceable. The tenant claimed that 200 percent was an unenforceable penalty; the landlord claimed it was a valid liquidated damages provision.

Ruling: The New York court ruled that the clause was enforceable.