In Denis v Truemner (2007), 84 OR (3d) 260 (Ont. S.C.J.), in dealing with the costs claimed in the action, Spies J. said:
 The disbursements claimed by the defendant are significant. They include airfare in the amount of $398.00 and online electronic legal research in the amount of $606.00. On its face, the amount for research is excessive as the defendant only referred to six cases. Airfare for counsel is not dealt with in the Tariff, although I have the power to award it if I find that this disbursement was reasonably necessary. I note the plaintiff claimed for mileage and parking in the amount of $477. I was advised that although both the plaintiff and defendant reside in Ottawa, the action was commenced in Toronto and the plaintiff requested in the claim that it be tried in Toronto. As it was reasonable for the defendant to retain Ottawa counsel, I find that that disbursement is reasonable. For these reasons I fix the defendant’s disbursements in the amount of $1,100.
How can we convince judges that good research might in fact be represented by counsel only referring to six cases rather than, say, the 25 or more he or she could possibly have found by using QL or some other database?