In the last edition of "Sedgwick's Elements of the Law of Damages" the author says (p. 232) that the subject of liquidated damages has been put in a new light by the two cases of the Sun Printing and Publishing Association v. Moore1 and the Clydebank R. &S. Co. v. Castaneda,2 and that they may be expected to have a considerable effect upon the further development of the law on the subject. The learned author then presents the old canons of interpretation with full illustration from the cases, followed by the citation of the decisions above mentioned, and concludes that in the light of these cases the old technical views of the canons of interpretation can no longer be regarded as conclusive. An examination of some of the cases recently decided may be helpful in determining the meaning of these decisions.3
Drake, Joseph H. "Liquidated Damages and Estoppel by Contract." Mich. L. Rev. 9 (1911): 588-94.