NOTE 23. ADD: East India Co v Henchman (1791) 1 Ves. Jun. 287 at 289 (30 E.R. 347 at 348); Wilson v Hurstanger Ltd [2007] EWCA Civ 299 at [35].

ADD AT END OF PARAGRAPH: Considerations of causation, such as those relevant to claims for common law damages, are not relevant (United Pan-Europe Communications NV v Deutsche Bank AG [2000] 2 B.C.L.C. 461 at [47]), but there must be a link between the profits in respect of which an account is sought and the fiduciary position or breach of fiduciary duty complained of: Button v Phelps [2006] EWHC 53 (Ch) at [66]; Murad v Al-Saraj [2005] EWCA Civ 959 at [85], [112] & [115]-[116], [2005] W.T.L.R. 1573; Chirnside v Fay [2006] NZSC 68 at [36]; Strother v 3464920 Canada Inc [2007] SCC 24 at [79] & [89]-[95].  Further, an account of profits can be rendered inappropriate where the claimant stands by for a length period before seeking the remedy, such that it is exposed to none of the risks involved but seeks all of the rewards and despite knowing about the breach: Edmonds v Donovan [2005] VSCA 27 at [77].