On September 25, 2009, the Toronto Stock Exchange (TSX) announced that, effective November 24, 2009, TSX-listed issuers will be required to obtain security holder approval when the number of securities issued in payment for an acquisition exceeds 25% of the number of issued and outstanding securities of the listed issuer that are outstanding (on a non-diluted basis), regardless of whether the acquired company is private or publicly held.
Blake, Cassels & Graydon LLP