Fuller and Perdue thus argued that "it is impossible to separate the law of contract damages from the larger body of motives and policies which constitutes the general law of contracts ... If this were possible the law of contract damages would indeed be simple, and we would have but one measure of recovery for all contracts. Of course this is not the case. What considerations influence the setting up of different measures of recovery for different kinds of contracts? What factors explain the rather numerous exceptions to the normal rule which measures damages by the value of the expectancy? It is clear that these questions cannot be answered without an inquiry into the reasons which underlie (or may underlie) the enforcement of promises generally." [L.L. Fuller & William R. Perdue, Jr., "The Reliance Interest in Contract Damages," 46 Yale L.J. (1936-37)]