Interesting discussion of equitable vs. non-equitable monetary relief: Bayer v. Neiman Marcus Group

The Ninth Circuit's recent opinion in Bayer v. Neiman Marcus Corp., ___ F.3d ___ (9th Cir. Jun. 26, 2017), contains a thought-provoking discussion of equitable vs. non-equitable forms of monetary relief.  See slip op. at 16-20. 

The case does not involve the UCL, and it considers federal law rather than California law, but the discussion resonates for me as I think about UCL restitution and the differences between restitutionary and non-restitutionary disgorgement.  Because of course I think about that all the time, especially on warm summer days like today.