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An order granting an account of profits awards a plaintiff the profits that the defendant received from the defendant’s misconduct. In Attorney General versus Blake, we explore whether a court may award an account of profits in a breach-of-contract case. George Blake worked for Britain’s Secret Intelligence Service. As a condition of his employment, Blake signed a contract agreeing not to disclose official information obtained through his employment in a book, either during or after his service. Blake later turned double agent and began providing valuable secret information to the Soviet Union. Blake ultimately pleaded guilty to various crimes and was sentenced to prison. He subsequently escaped and fled to Moscow. There, Blake wrote an autobiography that related, in part, to his time with British intelligence. Blake granted Jonathan Cape Limited exclusive publication rights in exchange for royalties, including £150,000 in advance royalties. None of the information contained in th

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