To show "fraudulent means or devices" insurers must establish the use by the insured of some lie to seek to improve or embellish the facts surrounding the claim. This defence was made out where the insured had represented in a false invoice that there had been a supply of equipment to the insured which had not taken place so as to obtain a benefit under the policy (Sharon's Bakery (Europe) Ltd v Axa Insurance UK plc [2011] EWHC 210 (Comm)).