- Parties: The appellant was Iris Technologies Inc. The respondent was His Majesty the King.

- Subject Matter: This case involved the implied undertaking rule, which prevented a party to a civil proceeding from using information that another party was compelled to produce for any purpose other than that proceeding. The rule would apply automatically and until the information was used in open court or was otherwise made public. The present dispute arose when the appellant commenced an appeal before the Tax Court of Canada. The Tax Court appointed a case management judge. The appellant brought a motion seeking confirmation that the implied undertaking rule did not apply to seven documents that the respondent provided. The appellant sought relief from the rule if it did apply. The Tax Court dismissed the appellant’s motion. The appellant appealed the Tax Court’s decision.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal. The appeal court saw no merit in the appellant’s argument that the Tax Court failed to consider the evidence when making its findings regarding the appellant’s purpose in requesting the documents. Instead, the appeal court found ample evidence in the record to support the Tax Court’s findings.

- Date: The hearing was set on Feb. 27, 2024. The court released its decision on Feb. 27, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: The court awarded costs in the all-inclusive agreed amount of $3,000.