THE tort of passing off is embedded in the world of commerce. Its roots are in an age when customers patronised local speciality shops. Today it operates in a world of e-commerce operating across national boundaries. To succeed in passing off, the claimant must show it has goodwill, that there has been a misrepresentation, and as a result that the claimant has suffered damage or, in a quia timet action, that there is the likelihood of damage. Necessary to establishing goodwill is not only that the claimant's goods and services have a reputation in the relevant jurisdiction, but also that the claimant has customers there. The question raised in Starbucks (HK) Ltd. v British Sky Broadcasting Group Plc. [2015] UKSC 31; [2015] 1 W.L.R. 2628 was whether this principle is still relevant in what Lord Neuberger described as “the age of global electronic communication” (at [1]). The Supreme Court held that it was.