The Royal Trust Co. owned shares in a company, and invited bids for them. Harvela bid $2,175,000 and Sir Leonard Outerbridge bid
"$2,100,000 or $101,000 in excess of any other offer… expressed as a fixed monetary amount, whichever is higher."
The Royal Trust accepted Sir Leonard's bid as being $2,276,000. Harvela sued for breach of contract, saying a referential bid was invalid. The Court of Appeal held in favour of The Royal Trust, that expressing a fixed amount made the referential bid valid.