An Ontario court has issued the first Canadian court decision to examine the meaning of "commercial activity" within the context of PIPEDA. The case involved a question of whether a recreational shooting association could be compelled to disclose its member list. The court relies heavily on the Privacy Commissioner’s guidance that for non-profit corporations "collecting membership fees, organizing club activities, compiling a list of members’ names and addresses and mailing out newsletters are not considered commercial activities." Case name is Rodgers v. Calvert.