The Supreme Court of Canada ruled that Israel was "clearly the most appropriate forum" for a multi-jurisdictional defamation suit brought by Canadian businessman Mitchell Goldhar against the Israeli media group Haaretz. The case concerned an article published by Haaretz which was critical of Goldhar’s management of a professional Israeli football team he owned. The article was published in Israel but was also available online in English and hence accessible to Canadians. Although Goldhar had reputational interests in both jurisdictions, he attempted to sue for defamation in the Canadian courts.  On appeal, the Supreme Court of Canada applied the simpliciter test and the forum non conveniens analysis to determine the most fair and efficient way to proceed based on convenience, expense, and ease of enforcement would be to move the hearing to Israel.