In the result, the plaintiff in this case was not seeking to profit from his illegal conduct (drinking and driving), nor was he circumventing the criminal law.
But reliance on markets also increases exposure to international market fluctuations, while women farmers are mainly smallholders and often unable to profit from export opportunities.
The delay in beginning to profit from the invention also reduces the company's recoupment in real terms, because dollars received in the future are worth less than dollars received today.