On this basis, I construe section 15(3) (which is the equivalent to section 128(3) of the Motor Accidents Compensation Act) as a preclusion from the award of Griffiths -v- Kerkemeyer damages unless the plaintiff can overcome one of the two thresholds by showing either that the gratuitous services are provided for a long period (ie more than 6 months) or that the services are provided for a significant period of time (ie more than 6 hours per week).

As in the case of negligent statements, one can be found liable in tort for failing to take reasonable care to perform a gratuitous service undertaken.

Critic David Denby put it this way: "pay it forward" meant to "perform an entirely gratuitous service for three people and then insist they do the same for three more.