In Labrecque v. Tyler, Master Bouck referred to R. 8-1(16) and held, without analysis, that:
 ... There is no discretion under the Rule to receive written argument in other circumstances. [other than applications over two hours]
However, in Simon Fraser University v. A&A Plumbing & Heating Ltd., released today, Master McDiarmid applied a somewhat more contextual analysis and found that only submissions which expand on the Notice of Application by raising additional facts or additional legal issues are considered "written arguments" prohibited by R. 8-1(16). Helpful written submissions which do not create surprise arguments and issues are permitted:
 Thus, no written argument can or should have been considered by the court.