 A second doctrinal challenge to the theory resides in the law’s acceptance—and apparent encouragement—of “efficient breach”. As noted above, the standard remedy for breach of contract, expectation damages, vindicates contractual rights through substitutionary relief: it provides disappointed promisees with a money award equal to their value of performance. The remedy of “specific performance”—a court injunction ordering the promisor to do as she promised—would more directly enforce the duty to perform. Yet specific performance is not the primary or usual judicial remedy. Moreover, the expectation remedy—in fact and perhaps also by design—encourages contractual promisors to breach when the costs of performance (including the opportunity costs of diverting performance to higher-valuing third parties) exceed the value of the promisee’s performance. If S promises to sell a widget for $10 to B, who values the widget at $15, and C offers to buy the same widget from S for $16, then the expectation remedy gives S an incentive to sell to C, pay B $5 in expectation damages, and pocket the additional dollar. The breach is efficient insofar as the widget ends up in the hands of the party that values it most, and this efficiency is cited (both in legal theory and by courts) as a reason for denying specific performance (N. Ind. Pub. Serv. Co. v. Carbon County Coal (1986)). By contrast, morality gives promisors no equivalent flexibility. This has dismayed some theorists who are attracted to contract as promise (Friedmann 1989). Others deny that there is any fundamental conflict, reinterpreting the expectation remedy in terms of an implied promise in the alternative, which allows promisors the choice of performing by trading a good for its price or by transferring money equal to the promisee’s value of trade (Markovits &amp; Schwartz 2011). Sophisticated parties have good reason to make contractual promises in this way, as doing so maximizes their gains from trade. But unsophisticated parties may think contracts require simple performance and view the legal option of substituting damages for performance as immoral.