Bibliographic record
Abstract
This case comment discusses AI Enterprises Ltd v Bram Enterprises Ltd [2014] SCC 12, a recent decision of the Supreme Court of Canada. The court held, substantially endorsing the majority reasoning in OBG v Allan, that only an actionable civil wrong could constitute unlawful means. However, the Canadian court justified this result on a conceptual premise that appears to differ from that assumed in OBG. Moreover, the Canadian court did not think it necessary to introduce the gloss that Lord Hoffmann propounded in OBG, viz that the illegal conduct must have interfered with the third party’s liberty to deal with the claimant. Further, the court critically evaluated a number of other strictures that had been previously applied to unlawful means. The result is a tort that bears close resemblance to that crafted in OBG but which also differs from it in subtle but important ways.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.004 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.001 | 0.003 |
| Science and technology studies | 0.027 | 0.008 |
| Scholarly communication | 0.007 | 0.002 |
| Open science | 0.002 | 0.003 |
| Research integrity | 0.007 | 0.007 |
| Insufficient payload (model declined to judge) | 0.007 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".