I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32 … [because without] such an order, the information would still be ‘out there’ in the possession of someone who should not have it” (Imerman at 621). There are, however, difficulties in applying this reasoning to the present case. While the circulated drafts of the respondents’ payitem bible contained content from the Payitem Bibles, edits were made over time, transforming the end-product into a new and unique document. At some point these drafts became the respondents’ own content, as opposed to infringing copies. The blanket order for delivery up being sought by the appellant would also compel the surrender of materials which the respondents are entitled to retain possession of. 71 We would add that an injunction and/or delivery up order are somewhat unsatisfactory remedies by themselves as they do not set right the loss already suffered by virtue of the respondents’ unconscionable conduct. Problematically, equitable monetary remedies do not guarantee more ideal outcomes (David Brennan, “A short argument in favour of all-proceeds remedies for breach of confidence” (2012) 17 MALR 232): A classic profits-based remedy requiring [the defendant] to disgorge his net monetary gains [from the breach] may be seen to present insurmountable problems of accounting because so much of [the defendant’s] own capital has been intermingled with the information in [the defendant’s] commercial use of it. Alternatively, making allowance for [the defendant’s] own capital might make the award very modest or even nominal. An award of money as equitable compensation for what [the plaintiff has lost] ― so that [the defendant] is obliged to put [the plaintiff] in the position [it] would have been in if the duty of confidence had not been breached ― creates such a wildly counter-factual basis of calculation that a court may rail against it as unduly speculative … 72 The appeal before us does not lend itself to an account of profits analysis because there was no finding of actual use of the appellant’s materials. The appellant faces the nearly “insurmountable” challenge of quantifying the portion of the third respondent’s proceeds attributable to the referencing and reviewing 34