The first claim against CIAFM was for 'money had and received'.
Spangaro faced an immediate problem in pursuing a claim in unjust enrichment against CIAFM. He himself had paid CIAFM nothing.
It seems clear that it was the third of the four propositions upon which Mr Spangaro was permitted to sue CIAFM in unjust enrichment.
In Spangaro, there was no need for the claimant to argue that CIAFM should be strictly liable in 'knowing receipt', for two reasons.
(82) The issue of whether the enrichment of CIAFM was at the expense of Mr Spangaro is discussed below Part III.