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Gateau is generally used for fancy, but light or rich, often with fresh decoration, such as fresh fruit or whipped cream.
Whereas a cake may remain fresh for several days after baking or even improve with keeping, a gateau usually includes fresh decoration or ingredients that do not keep well, such as fresh fruit or whipped cream.
You will find references to him in French culinary history books.
Cake recipes, Fannie Farmer's Boston Cooking School Cook Book  What is the difference between cake, gateau and torte? It generally denotes items made with delicate ingredients which are best consumed soon after the confection is made (gateaux des roi).
This is due to primarily to advances in technology (more reliable ovens, manufacture/availability of food molds) and ingredient availability (refined sugar). When removed the icing cooled quickly to form a hard, glossy [ice-like] covering.
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When tortes are multilayerd and fancifully decorated they are closer to gateaux EXCEPT for the fact they can last quite nicely for several days.
Cake & gateau: definitions & examples "Cakes and gateaux.