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Commentators have described section 39's adoption as the equivalent of a quiet revolution that is breathtaking in its potential transformation of the traditional contractual landscape.

Commentators have described section 39's adoption as the equivalent of a "quiet revolution" that "is breathtaking in its potential transformation of the traditional contractual landscape." Caprice L. Roberts, Restitutionary Disgorgement as a Moral Compass for Breach of Contract, 77 U. Cin. L. Rev 991, 993 (2009).

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