What are the damages recoverable from Rule 65(c) security?

Rule 65(c) does not define the damages that are recoverable from Rule 65(c) security. A number of courts and commentators, however, have indicated that restitution can provide an appropriate measure of damages. See Middlewest, 433 F.2d at 244 (Restitution is the proper remedy to return the parties to the position they would have been in had the [defendant] ... not been judicially restrained.); Littell v. Morton, 369 F.Supp. 411, 419 (D.Md.1974) ([U]nder the principle of restitution a party who obtains benefits from an improperly issued injunction, that he would not have received but for the injunction, has a duty to restore that benefit to those who have been injured by the injunction.), aff'd, 519 F.2d 1399 (4th Cir.1975) ; see also

[775 F.3d 143]