In finding that a lawyer's list of client names were not automatically protected by solicitor-client privilege, Trudel JA also disagreed with the taxpayer's arguments that client names are not part of a lawyer's accounting record, and that client names are as privileged as statements of account. She stated (at para. 57):
Statements of account are not the same as a lawyer's accounting records. The latter consist essentially of statements of fact such as the name of the client, the amount billed for the professional services, the payments received and the amounts still owed. Statements of account, by contrast, may reveal a history of the file. They may contain information including the nature of the consultation, a summary of communications between solicitor and client, and so on, which may be covered by solicitor-client privilege.