Reliance interest: P in pursuit of the K that D has breached took on expenses in reliance upon D keeping their promise. Thus P is compensated for their detriment as a result of D until they are returned to the position they were in prior to their reliance. Seeks to bring P back to 0 no further. (Example: The McCrae case- ship case, it was sunken. There was no ship. Difficult to compensate for something that they never had in the first place) Unjust impoverishment.