Geoffrey and Leueen Saldanha and Dominic Thivy were residents of Ontario and sold lots they owned in Florida to Frederick and Patricia Beals.

The Court applied the "real and substantial connection" test from the earlier decision of Morguard v. De Savoye to the international context.

He noted that the result in this case was overly harsh and unfair by imposing an 800,000 judgment on an 8,000 property due to essentially bad luck.

[2] He proposed that the real and substantial connection test be modified in the international context to reflect the added hardships imposed on litigating in a foreign country.

[5] and the Loewen case, where a Mississippi jury awarded 500 million in damages against a BC company for anti-competitive practices.