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In England and Wales the House of Lords case of Attorney-General v. Blake opened up the possibility of restitutionary damages for breach of contract. In this case the profits made by a defecting spy, George Blake, for the publication of his e-book, have been awarded to the British Government for breach of contract. The case has been adopted in English courts, but the conditions during which restitutionary damages will be out there remain unclear. In certain areas of the law another Law news head of damages has long been out there, whereby the defendant is made to give up the earnings made by way of the civil wrong in restitution. Doyle and Wright outline restitutionary damages as being a monetary treatment that is measured according to the defendant’s acquire somewhat than the plaintiff’s loss. The plaintiff thereby positive aspects damages which aren’t measured by reference to any loss sustained.