The taxpayer had to adapt its existing system for implementing a nation-wide health information system in Belize given the severe telecommunications and internet connectivity issues there. In finding that this project satisfied the test of technological uncertainty, Campbell J stated (at para. 31):
The Appellant had no reasonable expectation of success with the Belize project unless new knowledge could be obtained. …[T]he Appellant developed a new approach by creating a multi-write database replication system.
Before finding (at para. 42) that the taxpayer "had identified the problems with the project, developed its objectives, formulated hypotheses and testing scenarios and modified or re‑developed its approach in response to the results it was obtaining," she noted (at para.39) that:
While it will always be preferable that an appellant maintain contemporaneous documents to support its systematic investigative procedures and methods…the Act contains no legislative requirement to file those documents in order to qualify… .
Accordingly, the related expenditures gave rise to investment tax credits.