Several like-minded persons, including Seth, purchased land surrounding Lake Waban. The former owner of all the parcels wished to preserve Lake Waban in its natural setting for camping and fishing, and so inserted into the deeds, by which each purchaser took title, language sufficient to create an equitable restriction prohibiting the construction of any permanent structure thereon or the use for any purpose other than camping, fishing or related recreation. Pat took possession of the parcel owned by Seth, established various hiking trails thereon, hand-graded a campsite, and occupied and used the property in a manner and for a period sufficient to acquire title to it by adverse possession.

Assume for purposes of this question only that Seth made no attempt to convey the property to anyone. Instead, Pat executed a written contract of sale and a warranty deed conveying his interest in the parcel to Frank. Frank subsequently commenced construction of a lodge and boat launching facility on the parcel. Gary, owner of an adjacent parcel who had purchased from the original owner and had utilized his parcel for camping and fishing for 20 years, brought an appropriate action to enjoin Frank’s construction.

What is the likely outcome of Gary’s action?