Canada: Obtaining U.S. Discovery In Aid Of Canadian Litigation

Originally published in the February 2009 edition of Commercial Litigation Review.

In virtually every commercial case, we look for "hot documents" – those documents that tell the story with such impact that no witness could deny their truth. When a party fails to produce these documents, we go looking for them in the hands of non-parties. Canadian civil procedure allows for the discovery of this evidence, but typically only with leave of the court and only upon demonstrating fairness and necessity. As a result, orders for discovery of non-parties are the exception, not the norm, in Canada. Often, non-party evidence is simply out of reach of Canadian litigants. All is not lost, however: the evidence may be located in the United States.

U.S. federal law empowers district courts to permit any interested party to obtain discovery for use in a foreign proceeding from a person located in the district, even if this evidence could not be accessed under the rules governing the foreign proceeding.1 This legislative provision opens the door to Canadian parties gathering highly relevant information from U.S. sources, without seeking leave from a Canadian court. Counsel should use caution, however: Canadian courts have probably not yet given their last word on this litigation strategy, which, although expedient, may not sit well with Canadian judicial policy on the proper scope of discovery.

The Limits to Non-Party Discovery in Canada

In most Canadian jurisdictions, it is onerous to obtain discovery from non-parties. In Ontario, rules 30.10 and 31.10 of the Rules of Civil Procedure provide that discovery may be obtained from a non-party (whether by way of production of documents or examination for discovery) but only with leave of the court, upon showing a higher level of relevancy and proving that it would be unfair to require the moving party to proceed to trial without this discovery.2 An Ontario court shall not allow the examination for discovery of a non-party unless it is satisfied that (i) the moving party has been unable to obtain the information from other persons or from the person the party seeks to examine; (ii) it would be unfair to require the moving party to proceed to trial without having the opportunity to examine the person; and (iii) the examination will not unduly delay the commencement of the trial of the action, entail unreasonable expenses for other parties or result in unfairness to the non-party.3

Two judicial policies underscore limits on non-party discovery. First, non-parties should generally be immune from the intrusive, costly and time-consuming process of discovery.4 Second, the Rules articulate the view that the "effective and efficient resolution of civil lawsuits is not served if the discovery process takes on dimensions more akin to a public inquiry than a specific lawsuit."5 This latter policy – of limiting the scope and costs associated with discovery – has been reaffirmed repeatedly in Ontario in recent years, including in the 2003 Report of the Task Force on the Discovery Process in Ontario;6 in the 2007 Summary of the Findings & Recommendations of the Civil Justice Reform Project;7 and in the recent 2008 amendments to the Rules of Civil Procedure.8

As a result, orders for production from or discovery of non-parties remain the exception in Canadian commercial litigation.9

The U.S. Federal Courts' Willingness to Compel Discovery in Aid of Foreign Proceedings

By contrast, in U.S. federal courts, non-party discovery is available as of right.10 U.S. federal law allows foreign parties to take advantage of this style of discovery, for use in any international or foreign proceeding. 28 U.S.C. § 1782 reads in part:

(a) The district court of the district in which a person resides or is found may order him to give his testimony or statement or to produce a document or other thing for use in a proceeding in a foreign or international tribunal, including criminal investigations conducted before formal accusation. The order may be made pursuant to a letter rogatory issued, or request made, by a foreign or international tribunal or upon the application of any interested person and may direct that the testimony or statement be given, or the document or other thing be produced, before a person appointed by the court . . .

In Intel Corp. v. Advanced Micro Devices, Inc.,11 Advanced Micro Devices, Inc. (AMD) had filed an antitrust complaint against Intel with the Directorate General for Competition of the European Commission (DG-Competition), alleging that Intel had violated European competition law. After the DG-Competition declined AMD's recommendation to seek documents that Intel had produced in a private antitrust suit in the United States, AMD applied to a U.S. district court under § 1782 for an order directing Intel to produce those documents. The U.S. Supreme Court held that a U.S. district court has discretion to grant assistance in aid of a foreign interested party if (i) the evidence is sought from a person residing in the court's district; (ii) the applicant is an interested person; and (iii) the testimony or document sought are for use in a foreign proceeding. The Supreme Court held that assistance may be granted to any interested party, even if this party is not a litigant in the foreign proceeding (AMD was only a complainant before the Commission). Further, the foreign proceeding need not be pending or imminent, provided that it is within reasonable contemplation.

Section 1782 is far-reaching because it does not impose a foreign discoverability requirement: a party cannot resist a § 1782 application on the sole ground that the discovery could not be obtained in the foreign proceeding or that the interested party did not exhaust its avenues of discovery under foreign law.12 The U.S. Supreme Court went so far as to reject the argument that a § 1782 applicant must show that U.S. law would allow discovery in domestic litigation analogous to the foreign proceeding.

Although the Supreme Court rejected categorical limitations on the availability of § 1782, it suggested a number of factors to assist district courts in exercising their discretion, including

  1. whether the documents or testimony sought are within the foreign tribunal's jurisdictional reach, and thus accessible absent §1782 aid: U.S. courts have been more willing to allow discovery against non-parties on the theory that they would generally not be within the foreign tribunal's jurisdiction;

  2. the nature of the foreign tribunal, the character of the proceedings underway abroad and the receptivity of the foreign government or the court or agency abroad to U.S. federal court jurisdictional assistance: comity and parity may be legitimate touchstones for a district court's exercise of discretion;

  3. whether the § 1782 request conceals an attempt to circumvent foreign proof-gathering restrictions or other policies of a foreign country or the United States (discussed more fully below); and

  4. whether the subpoena contains unduly intrusive or burdensome requests.

U.S. courts have liberally granted assistance under § 1782. For example, courts have held that § 1782 requires only that the discovery sought be useful.13 The influential District Court for the Southern District of New York held in one case that the primary issue for the court is whether the applicant is pursuing discovery in good faith.14 The bounds of discovery available under § 1782 also appear to be expanding. For example, at least one district court has allowed the discovery of documents located abroad but within the control of a person located within the district.15 Several courts have held that interested parties to foreign arbitration may rely on § 1782.16

Impact of Lack of Foreign Discoverability on § 1782 Applications

What weight U.S. courts place on evidence that judicial assistance would circumvent foreign limits on discovery remains unclear. In In re Microsoft Corp.,17 for example, the district court denied Microsoft's request to access documents located in New York in the face of representations by the European Commission (the foreign tribunal at issue) that Microsoft was seeking to circumvent the Commission's access to file rules. The Court stated that it had not found a single case "where a court has granted § 1782 discovery in the face of express objection by the foreign court where the underlying proceeding is pending." Similarly, in In re Godfrey,18 the Court held that granting the aid requested would not be appropriate, "because the likelihood of interfering with Dutch discovery policy is substantial . . . petitioners would not have access to third party discovery outside the Netherlands."

By contrast, in In re Procter & Gamble Co.,19 the Court dismissed the argument that the discovery sought was broader than that permitted in the foreign proceeding: "Granting discovery under § 1782(a) would not undermine the policies of foreign governments in favor of low discovery costs because as a general rule it imposes no costs on such governments or on their inhabitants." It was of no moment that P&G had not exhausted its discovery opportunities in the foreign proceeding or that the foreign court was in a better position to determine whether the documents sought were relevant. The district court granted P&G's application because, in its view, denying discovery would lead to an inefficient, if not ineffective, process.

One explanation for the difference between P&G and Microsoft may be the courts' different appreciation of whether the foreign tribunal had a legitimate interest in limiting discovery. Short of Canadian authorities intervening before U.S. courts (as the European Commission did in Microsoft), however, expert evidence about Canadian law may do little to affect the grant of § 1782 aid. At least one U.S. court of appeal has suggested that "only authoritative proof that a foreign tribunal would reject evidence obtained with the aid of section 1782" is relevant and that such proof should be embodied "in a forum country's judicial, executive or legislative declarations."20 As discussed below, Canadian courts have stopped short of providing such guidance.

The Views of Canadian Courts on § 1782

There are few reported cases on the use of § 1782 by a Canadian party that has not first obtained a letter of request from a Canadian court.21 In CC Chemicals Ltd. v. Sternson Ltd,22 the defendant sought to examine for discovery the assignor of a Canadian patent, who resided in the United States. At the time, the Federal Court Rules allowed for this type of discovery as of right, but the Rules failed to provide the means to do so if the assignor was out of the court's jurisdiction. Therefore, the defendant obtained an order under § 1782 to examine the assignor in the U.S., for use in the Federal Court of Canada proceeding. On motion from the plaintiff, the Trial Division enjoined the defendant from carrying out the examination. The Federal Court of Appeal reversed the decision, holding that the defendant's actions did not warrant an injunction: the defendant had not circumvented the Federal Court Rules, but merely used § 1782 to fill in a procedural gap. Further, the § 1782 application did not otherwise interfere with the Canadian action (for example, the action had not been stayed). The Court of Appeal observed, however: "It may well be that the testimony could not be read at the trial, but it would be of use in preparing the appellant's case, which is one of the purposes of an examination for discovery."23

The British Columbia Court of Appeal also tacitly approved of the use of § 1782 in Penty v. Law Society of British Columbia.24 The central issue in Penty was the jurisdiction of the Law Society of British Columbia to gather testimonial evidence in the United States, but the Court of Appeal observed that "the order the Law Society obtained under § 1782 of Title 28 of the United States Code is unobjectionable." 25However, Penty does not address whether, or how, the Law Society might use the evidence so gathered at the relevant administrative hearing.

The most relevant recent case appears to be Vitapharm Canada Ltd. v. F. Hoffmann-La Roche Ltd.26 In Vitapharm, putative plaintiffs in an Ontario class action intervened in a parallel proceeding in U.S. district court to vary its protective order and thereby gain access to U.S. discovery. The Canadian defendants responded by filing a motion in Ontario Superior Court seeking to enjoin the plaintiffs from pursuing their motion before the U.S. court.

Justice Cumming held that the Superior Court had jurisdiction to grant the relief sought on the motion. However, he concluded that a "Canadian court generally will be reluctant to prevent someone from gathering evidence extraterritorially, as its ultimate admissibility in a Canadian proceeding will be determined by the Canadian courts."27 Justice Cumming therefore denied the injunction requested, noting that the plaintiffs did not seek to compel U.S. discovery but only to gain access to existing evidence. In the Court's view, the Canadian plaintiffs' course of action would lead to significant savings in litigation costs because, although the plaintiffs were not entitled to discovery before certification, the U.S. discovery would assist them in deciding what was irrelevant to the Canadian proceeding.

On appeal, the majority of the Divisional Court affirmed on the narrow ground that the plaintiffs were not seeking to compel discovery but only to gain access to existing evidence. In a concurring opinion, however, Justice Farley described Ontario's discovery rules extensively – one might speculate, to inform the U.S. court seized of the plaintiffs' motion of Ontario's relevant policies. Justice Farley went on to conclude that if the Canadian plaintiffs had asked the U.S. court to actively engage in discovery in the United States (rather than seek an amendment to a protective order), such a request "would then be an end run around Rules 30, 31 and 36.28 In such a case, he noted, "if the Canadian plaintiffs did engage in active sense discovery, then this (Canadian) Court would determine (a) whether the fruits of that labour could be employed in the Canadian proceedings and (b) the other sanctions for infringement of our discovery rules."29

The Ontario Court of Appeal reaffirmed Justice Cumming's order. The Court held that the plaintiffs' effort to gather evidence in the U.S. in accordance with the rules of that jurisdiction raised no comity concern, overriding policy or issue of fairness that would warrant issuing an injunction. Interestingly, the Court also turned down the appellants' suggestion that it provide guidance to the U.S. court about the governing rules of practice and procedure in Ontario, for the purpose of assessing § 1782 relief. The Court stated that such guidance, should it be necessary, could be provided by expert evidence adduced by the parties before the U.S. court.

The Current State of Play on § 1782

From these U.S. and Canadian cases, four propositions emerge. First, parties to Canadian proceedings may, relatively easily, obtain discovery from U.S. sources under § 1782. Although grants of § 1782 aid are discretionary, a survey of the case law turns up many cases in which U.S. courts have granted such applications.

Second, Canadian courts are, and will likely remain, reluctant to enjoin Canadian parties from gathering evidence in the United States in accordance with the rules of that jurisdiction. Such injunctions raise issues of international comity that extend beyond the propriety of allowing a party to gather additional evidence in a specific proceeding.

Third, permission to gather testimony and documents under § 1782 does not resolve the issue of how this evidence may be introduced at the Canadian trial. While the testimony and documents gathered from U.S. sources may always be useful to prepare one's case, having this evidence introduced at trial poses the same challenges as any other non-party testimony or documents. In many cases, a party will require leave of the Canadian court, whether to hold a commission to hear the evidence afresh or to have hearsay evidence admitted into the record despite rules of procedure and evidence to the contrary.30

Fourth, it remains to be seen how a Canadian court that has seen its process circumvented through a § 1782 application will deal with a request to introduce at trial evidence gathered in this way or, as Justice Farley noted, "whether the fruits of that labour could be employed in the Canadian proceeding" and what "the other sanctions for infringement of our discovery rules" would be.31 A Canadian court's answer to these questions will probably depend on its understanding of the policy underlying the limits on non-party discovery. If the court views the main goal of curtailing non-party discovery as protecting strangers from the cost and inconvenience associated with it, then the court may not object to these burdens being imposed, in accordance with U.S. law, on persons residing there. But if the court views the policy objectives as also including limiting the parties' discovery costs, then it may take a dim view of a party using a § 1782 application to open a new discovery front without prior leave of the court. In such a case, a Canadian court may consider sanctioning the use of this tactic and, possibly, excluding the evidence so obtained.

Section 1782 offers Canadian litigants an unparalleled procedure to obtain discovery from U.S. sources, especially from non-parties, but counsel should consider carefully how this evidence may ultimately be used at the Canadian trial.

Vincent de Grandpré practises litigation with an emphasis on intellectual property matters at Torys LLP in Toronto. He is admitted to practice in Ontario, Quebec and New York.


1.See 28 U.S.C. § 1782.

2.The evidence must go to a "material issue" in the proceeding. See, e.g., Lowe v. Motolanez (1996), 30 O.R. (3d) 408 (C.A.) at 413 ("The test for relevancy for non-party discovery is higher than that relating to obtaining production from a party in the action").

3.By contrast, in Newfoundland and Nova Scotia, any person may be examined for discovery as of right, subject to the court's discretion to disallow vexatious, improper or unnecessary examinations. See Nfld. Rules, rule 30.01(1) and N.S. Rules, rule 18.01(1).

4.See Ontario (Attorney General) v. Stavro (1995), 26 O.R. (3d) 39 (C.A.) at 12 [Stavro]; Goodman v. Rossi (1995), 24 O.R. (3d) 359 (C.A.) (discovery is an intrusion upon privacy interests).

5.Stavro, ibid. at para. 13.

6.Toronto: Task Force on the Discovery Process in Ontario, 2003, available at .

7.Coulter Osborne, Civil Justice Reform Project: Summary of Findings & Recommendations (Toronto: November 2007), available at .

8.R.R.O. 1990, Reg. 194 (last amended by Reg. 438/08), available at (and, in particular, rule 29.2 on proportionality in discovery).

9.See, e.g., Tribax Management Ltd. v. Laswind Investment Ltd., [2006] O.J. No. 3439 (S.C.J.) at para. 5 (QL).

10.Rule 30 of U.S. Federal Rules of Civil Procedure allows parties to stipulate to the discovery of any person (including non-parties), subject to certain limits and exceptions.

11.542 U.S. 241 (2004) [Intel].

12.The U.S. Supreme Court held so in spite of the European Commission's arguments that granting judicial assistance in these circumstances would encourage "fishing expeditions" and undermine the Commission's program offering prosecutorial leniency for admissions of wrong-doing. Intel, ibid. at page 2484.

13.See, e.g., In re Servicio Pan Americano De Proteccion, C.A., 354 F. Supp. 2d 269, at 271 (S.D.N.Y. 2004).

14.Minatec Fin. s.a.r.l. v. SI Group Inc., 2008 U.S. Dist. LEXIS 63802 at 26-27 (S.D.N.Y. 2008

15.In re Gemeinshcaftspraxis Dr. Med. Schottdorf, 2006 U.S. Dist. LEXIS 94161 at para. 5 (S.D.N.Y 2006).

16.See, e.g., Roz Trading Ltd., 469 F. Supp. 2d 1221, at 1223 (N.D. Ga. 2006).

17.428 F. Supp. 2d 188, (S.D.N.Y. 2006) [Microsoft].

18.526 F. Supp. 2d 417, at 423 (S.D.N.Y. 2007).

19.334 F. Supp. 2d 1112, at 1114 (E.D. Wis. 2004) [P&G].

20.Euromepa, S.A. v. R. Esmerian, Inc., 51 F.3d 1095, 1101 (2d Cir. 1995).

21.By contrast, there is no doubt that it is appropriate for a Canadian party to obtain the issuance of letters rogatory in Canada and then seek their enforcement in U.S. district courts under § 1782.

22.(1980), 116 D.L.R. (3d) 239 (F.C.T.D.), rev'd (1981), 124 D.L.R. (3d) 76 (F.C.A.) [CC Chemicals].

23.Ibid. at para. 18.

24.(1999), 68 B.C.L.R. (3d) 159 (S.C.) at 162, rev'd (1999), 69 B.C.L.R. (3d) 97 (B.C.C.A.) at 107-108, application for leave to appeal dismissed with costs, [1999] S.C.C.A. No. 616 [Penty].

25.Ibid. at para. 15.

26.[2001] O.J. No. 237 (S.C.J.), aff'd (2002), 212 D.L.R. (4th) 563 (Ont. Div. Ct.), aff'd (2003), 223 D.L.R. (4th) 445 (Ont. C.A.) [Vitapharm].

27.Ibid. (S.C.J.). at para. 45.

28.Ibid. (Div. Ct.) per Farley J. at para. 15.

29.Ibid. at para. 10.

30.For example, rule 31.11 of the Ontario Rules of Civil Procedure does not allow a non-party examination for discovery to be read into evidence at trial without an order of the trial judge. The Court would also need to conclude that this hearsay evidence meets the required thresholds of reliability and necessity.

31.Supra note 29

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.