We're not suggesting that a risk-based approach is not appropriate. What we were suggesting is that the number of incident reports related to counterfeit products is not a reasonable proxy for a more thorough risk assessment.
As the commissioner pointed out, many people aren't even aware that they should report these incidents to Health Canada when such an incident occurs or when they become aware of something, yet we've found—or it's our understanding, at least—that this is what the department uses to determine the risks of counterfeit in e-commerce in the Canadian marketplace. We don't believe that the number of incident reports is a reasonable proxy for a thorough risk assessment.