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In Hellboy Productions, Inc. v. Doe #1,1 the Federal Court granted the second attempt by Hellboy Productions Inc. (the Plaintiff) at a motion for a Norwich order, requiring a non-party Internet Service Provider (ISP) to identify the owners of IP addresses used to share the Plaintiff’s film online. The decision is a helpful reminder of the evidentiary requirements on a motion for a Norwich order.

Several significant judicial decisions were released in 2025 that remain relevant to businesses, commercial lenders and restructuring professionals. This bulletin summarizes the key developments of 2025 and highlights areas of significance for restructuring professionals and market participants to monitor in 2026.

The Alberta Court of King’s Bench has released a landmark decision providing the most comprehensive judicial interpretation to date of the “deemed ownership” and control provisions under the Special Economic Measures Act (SEMA). In RN Cardium Oil Inc. v. Loyal Energy (Canada) Operating Ltd, the Court summarily dismissed a $6 million contractual claim after concluding that payment would contravene Canadian sanctions.