Akenhead J in Phaestos Ltd v Ho

On an application for security for costs against a claimant company, the court applies the test in CPR 25.13(2)(c), requiring reason to believe that the company will be unable to pay the defendant's costs if ordered to do so; informal or unsubstantiated assurances or third-party 'guarantees' of financial support will not displace that conclusion unless they provide real, enforceable protection for the defendant.