Since the intangible benefits of buying a hybrid are difficult to quantify, calculating the payback usually focuses on the specific hybrid you buy, sales price differential to a standard car, projected gas costs, maintenance costs and tax rebates.

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The Electric Defender retains the four-wheel-drive hardware and differential lock of the standard Defender.

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The city argued, and the majority on the Court agreed, that this differential treatment still passed muster under the rational basis standard.

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