Noting the recent decision in Fiona Trust and Holding Corporation v Privalov, which observed that LIBOR had been widely used for setting interest rates in commercial cases, the court awarded interest at one per cent above LIBOR on a debt between two companies, departing from the conventional rate in commercial cases of base rate plus one per cent. The rate reflected the likely reference rate for a company in the position of the receiving party (Les Laboratoires Servier v Apotex Inc (2011).