A battle of the forms arises where two parties—often two companies—are negotiating the terms of a contract and each party wishes to contract on its own terms. For example, A offers to buy goods from B on A’s terms (the purchase terms), and B claims to accept A’s offer, but on B’s terms (the sales terms). At this point, there is no doubt that the parties have entered into a contract. But the question is, which terms actually apply? Purchasing, procurement and sales teams are often confronted with this situation, and if not managed properly, it can create a major blind spot in terms of risk. Some jurisdictions address this issue by applying specific principles. For instance, they may enforce the “first shot rule” or the “last shot rule”, whereby only the terms and conditions communicated first or last apply, while the others are eliminated. Other jurisdictions simply refer to contract law to settle such matters. Battle of the forms in Quebec Quebec courts simply refer to the general rules that apply to contract law, which are set out in the Civil Code of Québec1 (hereinafter the “CCQ”). Regardless of the means of communication used, a contract comes into force where and when the offeror receives acceptance of the offer. According to articles 1388 and 1389 of the CCQ, an acceptance sent to the offeror will only be deemed valid if it includes all of the essential elements of the offer. If not, the offer will be considered a counter-offer, which will be subject to the same terms and conditions, namely that the acceptance must include all of the essential elements. And if that is not the case, the response to the counter-offer will be considered a counter-counter-offer under article 1393 of the CCQ. This ping-pong situation can continue until the acceptance sent to the offeror is deemed valid. If a disagreement relating to the contract is considered “non-essential,” the courts defer to the parties’ common intention at the time the contract was drafted. Landmark decision: STMicroelectronics Inc. c. Matrox Graphics To this day, the landmark decision in this regard remains the decision in STMicroelectronics Inc. c. Matrox Graphics.2 In this particular case, there was a clause in the contract that required the buyer to acknowledge that the only courts with jurisdiction in the matter were the courts of the United States sitting in Dallas County, Texas: 19. GOVERNING LAWS: This contract will be governed by and construed in accordance with the laws of the State of Texas, and, in the case of an international sale of goods with respect to which the Convention on Contracts for the International Sale of Goods ("CISG") or any other law would otherwise apply, the Uniform Commercial Code as adopted in the State of Texas, and not CISG or any such other law, shall apply. Buyer agrees that it will submit to the personal jurisdiction of the competent courts of the State of Texas and of the United States sitting in Dallas County, Texas, in any controversy or claim arising out of the sale contract, and that service process mailed to it at the address appearing on the reverse side hereof by registered mail, return receipt requested, shall be effective service of process in any such court. On one side, STMicroelectronics Inc. was of the opinion that the above clause applied and that only the courts of the State of Texas and of the United States sitting in Dallas County, Texas, had jurisdiction. On the other, Matrox Graphics Inc. argued that it never explicitly or implicitly accepted the terms and conditions of STMicroelectronics Inc. At that point, the court examined the battle of the forms situation and had to determine whether the terms and conditions of STMicroelectronics Inc. or Matrox Graphics Inc. took precedence. The evidence shows that both parties’ representatives sincerely believed that their respective terms and conditions prevailed.3 The court concluded that the parties’ respective clauses complemented each other and could be read and applied together, as opposed to being mutually exclusive.4 The mere exchange of terms and conditions through purchase orders during each transaction was binding on the parties, and their silence regarding such terms and conditions was not exculpatory.5 Thus, the terms and conditions of both parties applied.6 The remaining question was that of the scope of Clause 5 of Matrox’s terms and conditions, which reads as follows: Terms and Conditions: . . . 5)  The Terms and Conditions will prevail notwithstanding any different or conflicting Terms and Conditions which may appear on any order acknowledgment submitted by the seller. The Court of Appeal judges indicated that this clause was open to different interpretations.7 The use of the word “prevail” in relation to conflicting clauses obviously required that there actually be a conflict between clauses. Matrox Graphics Inc. could not simply state that only its terms and conditions applied. In this case, the terms and conditions of Matrox Graphics Inc. did not include a clause regarding the courts’ jurisdiction  to hear a dispute. Thus, Clause 19 of STMicroelectronics Inc. applied.8 The court ultimately ruled that although STMicroelectronics Inc.’s Clause 19 applied, the wording of the clause was not sufficiently binding to force Matrox Graphics Inc. to litigate in Texas.9 Consequences of battles of the forms The following is a non-exhaustive list of the possible consequences of accepting the other party’s terms and conditions: A warranty that is longer (or shorter) than expected, or even no warranty at all. Unfavourable payment terms and legal proceedings in a different country in the event of non-payment. Unilateral changes to prices or requirements regarding products or services, or even potential penalties. Unforeseen transportation costs and terms and conditions. Restrictions on use or issues related to intellectual property. Deal with this issue in practice Here are a few tips to avoid confusion when applying the clauses of a given contract and prevent unintended interpretations of its terms and conditions: Negotiation of a master contract: Where there is an ongoing contractual relationship, negotiating a master contract is recommended to reduce the risk of ambiguity in the interpretation of clauses.  Addition of a clause in the purchase order: A buyer may include its terms and conditions of purchase in the purchase order and specify that only its general conditions apply to the contract. Alternatively, it may exclude any different or additional terms and conditions appearing on the seller’s documents. Although purchase orders are typically issued by the buyer, the seller may negotiate the addition of specific clauses to impose its terms and conditions of sale. Issuance of a confirmation slip: A confirmation slip is often sent upon receipt of a purchase order. It allows one party (usually the seller) to confirm acceptance of the order, while setting out the terms and conditions under which this acceptance is given. Just how effective this type of clause is really depends on how it is worded, so drafting it in clear terms that leave no room for interpretation is crucial. Outside Quebec: several possible solutions Any contract entered into outside Quebec may be subject to entirely different methods for resolving battles of the forms. In practice, there appear to be three widely accepted principles to address this issue. In Canada—with the exception of Quebec—the last shot rule is most commonly applied. According to this rule, the terms and conditions of whichever party is last to send or acknowledge the contract will apply. It is based on the general rules governing offers and acceptance. The landmark ruling in this regard was handed down by the Court of Appeal of England and Wales, which provided an essential clarification on this legal principle:10 In most cases, when there is a battle of the forms, there is a contract as soon as the last of the forms  is sent and received without objection being taken to it . . . In some cases, the battle is won by the man who fires the last shot. He is the man who puts forward the latest terms and conditions: and, if they are not objected to by the other party, he may be taken to have agreed to them . . . Another widely accepted principle is known as  the knock-out rule.  According to this rule, a contract is considered valid even where offer and acceptance do not perfectly match due to the differing general conditions. The terms governing the contract are those that are common in substance in the general conditions of both the seller and the buyer. The differing terms cancel each other out and are replaced by the default rules provided for by the applicable law. The knock-out rule applies in several countries, including the United States, France and Germany.11 The big downside is that, when applied, it generally excludes the applicable law clause, which is commonly found in both sales and purchase terms and conditions and sets out choice of forum and choice of law clauses that typically differ. The last of the three principles is called the first shot rule, whereby the terms and conditions contained in the first contractual offer prevail over subsequent ones.12 Although this principle is not as popular or frequently applied as the others, it is used and codified in Article 6:225 of the Civil Code of the Netherlands.13 Ultimately, it seems that each jurisdiction applies its own principle, with no particular one being regarded as superior to the others. Although Quebec does not apply any of the principles, it does seem to favour the last shot rule, which can lead to a ping-pong situation. In such cases, the challenge lies in determining which party sent the final version of the contract. Written with the collaboration of Me Laure Pinlon, Director of Legal Affairs at Luqia Technologies. Specifically, articles 1387 et seq. and 1425 et seq. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784 STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCS 31, para. 26. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784, para. 62. Achilles (USA) c. Plastics Dura Plastics (1977) ltée/Ltd., 2006 QCCA 1523, para. 24. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784, para. 40. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784, para. 51. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784, para. 62. STMicroelectronics Inc. c. Matrox Graphics Inc., 2007 QCCA 1784, para. 126. Butler Machine Tool Co Ltd. v Ex-Cell-O Corp (England) Ltd. [1977] EWCA Civ 9 (25 April 1977), para. 62. Giesela Rühl, “The battle of the forms : comparative and economic observations”, (2003) 24:1 University of Pennsylvania Journal of International Economic, pp. 198 and 199. John Henry Davis, “Defense of the Battle of Forms: Curing the First Shot Flaw in Section 2-207 of the Uniform Commercial Code” (1973) 49:2 Notre Dame Law 384, p. 389. Burgerlijk Wetboek (Civil Code of the Netherlands), Book 6, Article 6:225.

Financing infrastructure, whether it involves maintaining the infrastructure we’ve inherited, building the infrastructure we need today, or anticipating the infrastructure that will be required in the future, is one of the greatest challenges facing modern societies. Civil, industrial and energy infrastructure are essential assets for the common good, and their maintenance and modernization require colossal investments. However, public finances are limited, which restricts the ability of governments to act alone. In this context, it is crucial to use all available financing methods by incorporating private capital and designing innovative financial tools. In this spirit, we will be publishing a series of six articles devoted to infrastructure financing in Quebec and Canada. In them, we will discuss the issues related to these strategic investments and highlight realistic solutions to address them. This first article begins by providing an overview of the situation in Quebec and Canada, and then looks at the current challenges and the solutions that will shape the infrastructure of tomorrow. The Current Situation in Quebec and Canada In Quebec, public investment in infrastructure is governed by the 2025-2035 Québec Infrastructure Plan (the “QIP”), which provides for the injection of $164 billion over 10 years1. The QIP is a government planning document identifying and prioritizing major infrastructure projects in all public sectors. The most recent version of the QIP pays particular attention to the longevity of the existing infrastructure. Keeping current public assets in good condition despite the chronic maintenance backlog will absorb nearly 65% of the planned funding. The investments are primarily directed towards road transport ($36 billion), healthcare ($28 billion), education ($23 billion), and public transit ($9 billion). In terms of energy infrastructure, Quebec has embarked on a major transformation. According to Hydro-Québec’s Action Plan 2035, the province has set itself the objective of doubling its electricity generation capacity by 2050, with an intermediate target of adding 60 terawatt-hours (TWh) in 2035. This plan involves investments of over $100 billion for the construction of new dams, wind farms, and electric transmission networks in order to meet the growing demand related to electric vehicles and the energy transition2. Energy issues are a top priority across Canada. We are witnessing a resurgence of nuclear power, with several provinces (Ontario, New Brunswick, Alberta and Saskatchewan) choosing to develop small modular reactors (SMRs) to decarbonize their energy generation and ensure energy security3. At the same time, there is strong pressure to build new pipelines for hydrocarbon exports, particularly to Asia and Europe, for the energy transition and supply security4. At the federal level, the 2025 budget gives concrete form to Prime Minister Mark Carney’s investment ambitions5 to address critical issues such as housing, public transit, climate resilience, and accessibility. One of the flagship programs at the federal level is the creation of Build Canada Homes6, a new agency established in September 2025 with a budget of $13 billion. This program aims to “supercharge” the construction of affordable housing, to leverage public land, and to make use of modern techniques such as modular and mass timber construction. Meanwhile, on September 11, the Prime Minister announced an initial nationwide series of energy, port, and mining projects. He also expressed the desire to add other projects in the coming years. This list includes the expansion of the Port of Montreal in Contrecœur. Current Challenges The asset maintenance deficit, that is, the estimated amount of infrastructure in poor or very poor condition, is estimated by the Quebec government to be over $40 billion in 2025. That’s the amount that would need to be invested today simply to bring systems back to an acceptable state. In addition to rehabilitating aging infrastructure, it’s also important to make existing infrastructure more resilient; for example, in 2024, the flooding further to Hurricane Debby caused $2.5 billion in damage in southern Quebec7. And infrastructure must be low-carbon, in order to allow Quebec to achieve its climate objectives in terms of greenhouse gas emission reduction. Furthermore, modernization must incorporate climate change adaptation, cybersecurity, and smart grids. We need to accelerate the construction of new infrastructure to ensure Canada’s prosperity. In 2023, the Canada Mortgage and Housing Corporation noted that 3.5 million new homes will be needed by 2030 to restore affordability in the country8. Added to this are the needs for energy, transportation and healthcare infrastructure, which are intensifying due to population growth, the energy transition, the desired reindustrialization and, in the future, the increasing use of energy-intensive artificial intelligence. However, in addressing these challenges, governments are facing a critical lack of liquidity. The 2025 federal budget in Ottawa includes a $78-billion deficit9, while the Government of Quebec’s budget includes a record $13.6-billion deficit10. These structural deficits considerably limit their budgetary leeway and force them to choose between the different issues our societies face. At the municipal level, municipalities are legally required to table a balanced budget. Given the rising expenses and the electoral need to not increase taxes significantly, potential investments are limited. Potential Solutions: Private Capital and Financial Innovation Faced with increasing pressure on public finances, particularly at the municipal level, governments can no longer bear the cost of modernizing and developing infrastructure alone. In this context, looking to private capital and financial innovation can bridge the gap between public financial needs and capacities. Some of the top solutions are public-private partnerships, smart pricing (tolls, usage fees, dynamic pricing), and mobilizing institutional savings, particularly through pension funds, insurance companies and investment funds. Pension funds and insurance companies are particularly attracted to infrastructure projects. Their long-term investment horizon is well aligned with the lifespan of the projects and the stable revenue streams they generate. For example, the Fonds de solidarité FTQ has a fund dedicated to real estate11. Banks are key partners in infrastructure projects. They offer hybrid financing, combining low-interest loans and government backing to secure investments in critical projects such as highways, bridges and railways. It is also worth noting that investment funds are increasingly turning to infrastructure financing, as evidenced by the example of BlackRock12. BlackRock recently strengthened its position in this sector by acquiring Global Infrastructure Partners for $12.5 billion, creating a leading investment platform in private infrastructure markets. This acquisition, combined with strategic partnerships with players like Microsoft, aims to meet the growing demand for essential digital and energy infrastructure to support technological advances and the digital economy. Furthermore, the purchase of key Panama Canal ports for $23 billion demonstrates BlackRock’s commitment to critical infrastructure assets globally. These investments, motivated by the desire to diversify portfolios and protect against inflation, allow for the integration of professionals in the execution of projects. While these approaches make it possible to diversify funding sources, accelerate project completion and distribute risks between the public and private sectors, they also raise issues of governance, transparency and social acceptability, which require special attention to protect the long-term public interest. Infrastructure financing in Quebec and Canada must evolve to address the maintenance deficit, the requirements of the energy transition, and increasing budgetary constraints. Private capital, whether from pension funds, banks or specialized funds, offers indispensable support for collective efforts. Beyond the diversification of funding sources, the emergence of contractual and financial innovations, such as performance contracts, green bonds and risk-sharing models, opens up new ways to attract private investors while protecting the public interest. Our next article will discuss these new tools and mechanisms in detail, as well as the conditions for their success in Quebec and Canada. Government of Québec (March 25, 2025). Plan québécois des infrastructures 2025-2035 : le gouvernement du Québec se donne les moyens de réaliser ses engagements et de soutenir l’économie québécoise.  https://www.quebec.ca/nouvelles/actualites/details/plan-quebecois-des-infrastructures-2025-2035-le-gouvernement-du-quebec-se-donne-les-moyens-de-realiser-ses-engagements-et-de-soutenir-leconomie-quebecoise-61815 Hydro-Québec (2 novembre 2023). Vers un Québec décarboné et prospère. Plan d’action 2035 d’Hydro-Québec. https://www.hydroquebec.com/data/a-propos/pdf/plan-action-2035.pdf Canada Energy Regulator (August 20, 2025). Market Snapshot: Canada’s role in small modular reactor (SMR) technology. https://neb-one.gc.ca/en/data-analysis/energy-markets/market-snapshots/2025/market-snapshot-canadas-role-in-small-modular-reactor-smr-technology.html Underground Infrastructure (September 2025). Canada eyes new pipelines to boost energy security, cut U.S. reliance. https://undergroundinfrastructure.com/magazine/2025/september-2025-vol-80-no-9/features/canada-eyes-new-pipelines-to-boost-energy-security-cut-us-reliance Prime Minister of Canada (November 2025). Prime Minister Carney shares Budget 2025 plan to build communities strong. https://www.pm.gc.ca/en/news/news-releases/2025/11/05/prime-minister-mark-carney-shares-budget-2025-plan-build-communities Government of Canada (September 14, 2025). Prime Minister Carney launches Build Canada Homes to supercharge homebuilding across the country. https://www.pm.gc.ca/en/news/news-releases/2025/09/14/prime-minister-carney-launches-build-canada-homes Insurance Bureau of Canada (September 13, 2024). The costliest severe weather event in Quebec’s history – August flooding caused nearly $2.5 billion in insured damage. https://www.ibc.ca/news-insights/news/the-costliest-severe-weather-event-in-quebec-s-history-august-flooding-caused-nearly-2-5-billion-in-insured-damage Canada Mortgage and Housing Corporation (June 23, 2023). Housing Shortages in Canada – Update on how much housing we need by 2030. https://assets.cmhc-schl.gc.ca/sites/cmhc/professional/housing-markets-data-and-research/housing-research/research-reports/2023/housing-shortages-canada-updating-how-much-we-need-by-2030-en.pdf CBC (November 4, 2025). Budget fédéral : dépenses de taille, compressions humbles et un déficit qui se creuse. https://ici.radio-canada.ca/rci/fr/nouvelle/2205360/budget-federal-depenses-compressions-investissements-deficit-2025 Royal Bank of Canada (March 25, 2025). Quebec Budget 2025: Record deficit and a long and conditional path to balance. https://www.rbc.com/en/economics/canadian-analysis/provincial-and-fiscal-outlooks/provincial-budgets-and-economic-statements/quebec-budget-2025-record-deficit-and-a-long-and-conditional-path-to-balance/ Fonds immobilier de solidarité FTQ (2025). Who we are. https://www.fondsftq.com/en/business/fonds-immobilier/who-we-are Business Economy (March 6, 2025). Why BlackRock is Investing Heavily in Infrastructure. https://www.businesseconomy.com/latest-news/why-blackrock-is-investing-heavily-in-infrastructure/

In a previous Bulletin, the authors broadly outlined the legal framework that applies to export controls, as well as the challenges surrounding large language models in artificial intelligence in an era of knowledge sharing. Given that a number of legal and geopolitical developments covering various aspects of this topic took place in 2025, a brief overview is timely on the potential implications for the development of your AI projects, with a special mention of generative AI (or “GenAI”), as the new year begins. What are export controls? Export controls establish rules designed to curb the risk of transferring military, strategic and dual-use (civilian and military) goods and technologies to destinations deemed contrary to national security interests. Such technologies can take on various forms, ranging from physical hardware to technical information. In Canada, export controls are based on a licensing system, under which permits are given based on a series of items listed on the Export Control List (“ECL”) under the Export and Import Permits Act (“EIPA”). To find out if parts of your AI projects are subject to export controls, you should primarily (but not exclusively) refer to that list and to the guide prepared to better understand the list. Key events in 2025 Order SOR/2025-89  On March 7, 2025, an Order amending the ECL was published in the Canada Gazette, in an effort to include emerging technologies that are increasingly faster and more scalable, the capabilities of which raise concerns about potential adversarial military applications.1 Of particular interest in this context, subitem 5506(1) of the schedule to the ECL has been replaced by a number of paragraphs and subparagraphs. But what do these changes mean for AI projects in practice? The amendments made to subitem 5506(1) do not target AI applications (algorithms, models, data), but rather: extreme ultraviolet (“EUV”) lithography equipment, namely EUV masks and reticles making it possible to use this technology to manufacture advanced integrated circuits; cryogenic cooling equipment and ultra-sensitive amplifiers for quantum computers; advanced semiconductor materials; development and production softwares related to certain of the foregoing technologies.2 In other words, subitem 5506(1) targets the industrial toolbox used to build advanced computers, in particular through its inclusion of EUV lithography, which is used for cutting-edge integrated circuits and quantum computers that are revolutionizing the world of advanced computing. It can therefore be said that these rules affect the AI industry because of a form of hardware dependence, since tight control over these infrastructure manufacturing technologies necessarily affect the ability of a country or company to develop and operate advanced AI. In sum, these latest amendments are simply the continuation of those made in the previous year’s Order, which targeted the fields of quantum computing and advanced semiconductor manufacturing in particular (GAAFETs, representing next-generation integrated circuits).3 It has yet to be ascertained how the aforementioned orders will directly affect typical GenAI projects (model development, AI SaaS services, etc.). Those who will experience the more direct repercussions are suppliers of advanced computing equipment and businesses doing R&D on semiconductors, integrated circuits and quantum computing. Notice to Exporters No. 1159 Apart from the technical components, a certain complexity arises when we understand that the definition of a “technology” subject to export controls within the meaning of the law is meant to be broad, and that it includes technical data, technical assistance and information necessary for the development, production or use of an item appearing on the ECL. In other words, the scope of the technologies concerned goes beyond simple physical components or equipment. This is especially true given the proliferation of often cross-border cloud-based solutions, which make technical knowledge accessible digitally and circulate it far and wide. Given this context, it is appropriate to read the Guidance on the movement to and storage of controlled technology in the Cloud (Notice to Exporters No. 1159), published in November 2025 by the Government of Canada. The document was prepared to clarify instances when the use of cloud services constitutes a transfer of controlled technology under the EIPA, requiring a permit.4 In summary, the guidelines state that: it may be considered a transfer if a controlled technology is disclosed from a place inside Canada to a place outside Canada; a controlled technology is considered disclosed if it is sent from Canada and stored in a foreign location in a way that creates a reasonable possibility that a person located outside Canada would be in a position to examine that technology; a reasonable possibility means more than a mere possibility, but less than the standard of “more likely than not”; the location of servers hosting controlled technology only matters if it affects the reasonable possibility that the technology could be disclosed outside Canada; in general, it is considered a transfer when a person located outside Canada holds decryption keys or routine access rights that create more than a remote possibility that the technology may be examined, or when a cloud service provider creates an unencrypted backup copy that contains controlled technology to restore a system after an incident, and that such copy is stored on servers outside Canada where foreign administrators can access it; when cloud services are used, both the owner of the controlled technology and the cloud service provider have a degree of care and control of the technology. Thus, not only is there a risk of knowledge sharing where items directly listed on the ECL are involved (whether to manufacture them or otherwise), but the possibility of violating export controls also exists because of the interaction between cloud services and the knowledge that could be transferred (within the meaning set out above), if the cloud contains information about or relates to a controlled technology. Considerations regarding GenAI What about GenAI projects? Despite all of the above, these projects may still suffer indirect repercussions, and not only on highly technical components. You will need to exercise a certain degree of caution regarding the compliance of your GenAI projects because of the amount of information they can accumulate through the various layers of their structure. Training data There are the data used during the GenAI’s learning phase, before it is rolled out. The amount of this data can be massive, and it can be structured or unstructured. It is used to provide a knowledge base for the model and enable it to produce relevant outputs when it is given inputs. The learning phase is risky if the datasets contain controlled technical information and if the data can be regurgitated or combined when users use the GenAI. The GenAI’s weights, filters, and other operating parameters These parameters can be compared to physical control buttons—they are adjusted during the GenAI’s training and during the configuration of the solution that uses it. They determine how much each input element will influence the response and refine the model (i.e., the structure that allows the GenAI to interpret inputs and generate outputs). In the United States, weights in particular are a hot topic considering the country’s export policy, under which they can constitute key parameters for the most advanced AI models. Inputs This is the data provided by users to generate relevant outputs (e.g., text, images, structured data) when the GenAI is already rolled out. Such data is used to trigger a response or behaviour from the model. Just like with training data, inputs will be critical depending on the use made of the model and the information disclosed to obtain a response. Conditions consistent with legal requirements must be provided to prevent the model from being contaminated by sensitive data after it is rolled out, especially if it stores all the inputs provided to it for its continued learning. Outputs This is what GenAI generates in response to inputs. Outputs can be in the form of text responses or images, codes, or even data-based predictions. Given the above, it will be challenging depending on the datasets conveyed by the GenAI, to ensure that outputs do not violate export controls, as they could make it possible to indirectly obtain information the direct access to which would otherwise be prohibited. Conclusion We can imagine that the recent changes to export controls in Canada are just the beginning of an effort to address new concerns arising from this rapidly changing and ever more powerful technology. Export controls are also not devoid of a diplomatic context. For now, making AI subject to export controls seems to be the preferred mechanism to curb the exponential powers of such technology in Canada. The extent to which this will be done remains to be seen and will be interesting to follow. Government of Canada, Order Amending the Export Control List: SOR/2025-89 (March 7, 2025): Canada Gazette, Part II, Volume 159, Number 7: Order Amending the Export Control List: This is not an exhaustive list, but rather a few relevant examples that apply to advanced computing. Government of Canada, Order Amending the Export Control List: SOR/2024-112 (May 31, 2024): Canada Gazette, Part II, Volume 158, Number 13: Order Amending the Export Control List: Government of Canada, Notice to Exporters No. 1159 – Guidance on the movement to and storage of controlled technology in the Cloud (amended November 10, 2025): Notice to exporters no 1159 – Guidance on the movement to and storage of controlled technology in the Cloud