Seedlings Life Science Ventures LLC v Pfizer Canada Inc [2018] HIPR 13 (FC)

The implied undertaking rule is a now well accepted principle of Canadian common law, pursuant to which a party to whom documents or information are transmitted in the course of pre-trial discovery is taken to have given an undertaking to the Court that he or she will not disclose or use them for any purpose other than the litigation in which they are produced. Any collateral or ulterior use constitutes a contempt of Court.