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It is not necessary under § 2-712 that the buyer establish market price. Duesenberg and King, Sales and Bulk Transfers under the U.C.C. § 14.04 Matthew Bender (1974). Where the buyer complies with the requirements of § 2-712, his purchase is presumed proper and the burden of proof is on the seller to show that 'cover' was not properly obtained. Spies, Sales, Performance and Remedies, 44 Tex. L. Rev. 629, 638 (1966). 

As White and Summers point out, 'Since 2-712 measures buyer's damages by the difference between his actual cover purchase and the contract price, the formula will often put buyer in ...