The complaint contested the decision by the Department of Justice Canada (Justice) to withhold the entire content of a Memorandum of Understanding (MOU) for the provision of legal services under section 23 (Legal advice and litigation privilege) of the Access to Information Act. Justice could not show that section 23 applied to the entirety of the record at issue – in particular, that the general identifying information such as the title of the MOU and the signature blocks are protected by the solicitor-client privilege. It was also determined that Justice had waived its solicitor-client privilege over some information in the MOU and therefore that particular information was not protected anymore. The complaint is well founded. The Information Commissioner recommended that Justice release part of the record and Justice has communicated its intention to implement this recommendation.