[36] In the present case, the Appellant has adduced evidence of a product improvement that benefitted the company but there was insufficient evidence for me to conclude that a scientific or technological advancement occurred. Product improvement alone is insufficient to bring a taxpayer within the SR&ED provisions contained in the Act. … The evidence supports that well-known, routine programming tools were used to develop and improve upon the procedure of reporting to clients efficiently and quickly in a real-time environment.
[37] … The fact that the third party products belonging to Bayside and ActFax were unknown was an additional challenge encountered by the Appellant, but it cannot by itself constitute a technological uncertainty.
2037625 Ontario Inc. (ITC Invoice to Cash Inc.) v. The Queen 2015 TCC 269 (D Campbell)