A stress measure is work-conjugate to a strain measure when their contraction gives the mechanical power per specified volume for every admissible deformation rate. The reference-volume power is , with Kirchhoff stress tensor and rate-of-strain tensor . A strain constraint can leave the conjugate stress undetermined by a reaction component that does no admissible work; uniqueness should therefore not be assumed on a restricted set of rates.
Use the material-first nominal stress and . The symmetric Biot stress conjugate to the Biot strain tensor is . To prove it, set and differentiate . Conservation of angular momentum makes symmetric, so the contraction of with is zero: it is a contraction of a symmetric tensor with a skew tensor after cyclically moving . Thus . No assumption that itself is symmetric is needed.

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