^ Simons & Cardi, supra note 138, at 351 & n.9 (“[O]n Ripstein’s theory, it would seem that purposely contacting a person would be an impermissible battery while knowingly contacting the person ordinarily would not, since a knowing interference with a person’s rights that is a mere side effect of the actor’s purposes is not readily conceptualized as an impermissible using. Yet either circumstance supports battery liability.”).
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