In the May 2010 issue of Construction Canada, this author wrote an article—“Ontario: The New Rules of Practice”—that examined how changes in the province were intended to reduce costs and delay in litigation, and facilitate the early and fair resolution of disputes. Two years after the rule has become law, the question is whether it is working. One of the changes was the provision of a summary judgment in litigation cases without a trial (Section 20 of the Rules of Civil Procedure). The Rule 20 amendments took up some four and a half pages; they were bound to attract the scent of controversy, and lawyers quickly engaged in swarms of summary judgment cases.