B2C2 Ltd v Quoine Pte Ltd: Security for Costs Application in Cryptocurrency Trading Dispute

In B2C2 Ltd v Quoine Pte Ltd, the Singapore International Commercial Court addressed an application by Quoine Pte Ltd (Defendant) for security for costs against B2C2 Ltd (Plaintiff), a UK-based company, in a dispute arising from reversed cryptocurrency trades on Quoine's platform. The court, presided over by Simon Thorley IJ, dismissed the application, finding that the balance of factors favored not granting security, considering B2C2's established status and compliance with court orders.

1. Case Overview

1.1 Court

SINGAPORE INTERNATIONAL COMMERCIAL COURT of the republic of singapore

1.2 Outcome

Application dismissed

1.3 Case Type

Civil

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Security for costs application in a dispute over reversed cryptocurrency trades. The court dismissed the application, finding the balance favored not granting security.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Quoine Pte LtdDefendantCorporationApplication dismissedLost
B2C2 LtdPlaintiffCorporationApplication dismissedWon

3. Judges

Judge NameTitleDelivered Judgment
Simon ThorleyInternational JudgeYes

4. Counsels

Counsel NameOrganization
Ivan LimAllen & Gledhill
Marrissa KarunaAllen & Gledhill
Paul OngAllen & Gledhill
Danny OngRajah & Tann Singapore LLP
Rachel LowRajah & Tann Singapore LLP
Sheila NgRajah & Tann Singapore LLP

4. Facts

  1. The Plaintiff is a UK-registered company trading as an electronic market maker.
  2. The Defendant is a Singapore-registered company operating a currency exchange platform.
  3. The Plaintiff placed ETH/BTC orders on the Defendant’s platform on 19 April 2017.
  4. The Defendant unilaterally reversed the trades due to a 'technical glitch'.
  5. The Plaintiff contends that the reversal of trades constituted a breach of agreement.
  6. The Defendant sought further security for costs from the Plaintiff.
  7. The Plaintiff had already provided S$80,000 as security for costs.

5. Formal Citations

  1. B2C2 Ltd v Quoine Pte Ltd, Suit No 7 of 2017 (Summons No 14 of 2018), [2018] SGHC(I) 08

6. Timeline

DateEvent
Plaintiff placed ETH/BTC orders on Defendant’s platform
Plaintiff provided S$80,000 as security for costs
Action transferred to the Singapore International Commercial Court
First judgment given on application for summary judgment
Second judgment given on the question of disclosure of confidential information
Defendant filed an application for security for costs
Hearing date
Letter from the Plaintiff
Letter from the Defendant
Judgment reserved
Judgment date

7. Legal Issues

  1. Security for Costs
    • Outcome: The court dismissed the application for further security for costs, finding that the balance of factors favored not granting security.
    • Category: Procedural
    • Sub-Issues:
      • Foreign residency as a ground for security for costs
      • Application of Order 23 and Order 110 of the Rules of Court
      • Discretion of the court in ordering security for costs

8. Remedies Sought

  1. Unspecified (related to the reversed trades)

9. Cause of Actions

  • Breach of Contract

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Finance
  • Technology

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
B2C2 Ltd v Quoine Pte LtdSingapore High CourtYes[2017] SGHC(I) 11SingaporeCited for a prior judgment on an application for summary judgment under O 14 of the Rules of Court.
B2C2 Ltd v Quoine Pte LtdSingapore High CourtYes[2018] SGHC(I) 04SingaporeCited for a prior judgment on the question of disclosure of confidential information.
Jurong Town Corp v Wishing Star LtdSingapore Court of AppealYes[2004] 2 SLR(R) 427SingaporeCited for the principles to be applied in considering the exercise of discretion in cases where a foreign plaintiff is involved regarding security for costs.
Pacific Integrated Logistics Pte Ltd v Gorman Vernel International Freight LtdSingapore High CourtYes[2007] 1 SLR(R) 1017SingaporeCited for the principle that proof of a plaintiff's residence outside Singapore is a threshold condition under O 23 r1(1)(a), rather than a conclusive indicator that security should be ordered.
Creative Elegance (M) Sdn Bhd v Puay Kim SengSingapore High CourtYes[1998] SGHC 171SingaporeCited regarding security for costs.
Aeronave v Westland Charters LtdUnknownYes[1971] 1 WLR 1445UnknownCited regarding security for costs.
Teras Offshore Pte Ltd v Teras Cargo Transport (America) LLCSingapore International Commercial CourtYesSingapore International Commercial Court Suit No 1 of 2016SingaporeCited for a ruling on security for costs in a case transferred from the High Court to the SICC.

13. Applicable Rules

Rule Name
Order 23 of the Rules of Court
Order 110 Rule 45 of the Rules of Court

14. Applicable Statutes

Statute NameJurisdiction
Rules of Court (Cap 322, R 5, 2014 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Security for costs
  • Cryptocurrency
  • Virtual currency
  • ETH/BTC
  • Technical glitch
  • Unilateral reversal
  • Foreign corporation
  • Order 23
  • Order 110
  • Singapore International Commercial Court
  • Rules of Court

15.2 Keywords

  • Security for costs
  • Cryptocurrency
  • Singapore International Commercial Court
  • B2C2
  • Quoine
  • Order 23
  • Order 110

17. Areas of Law

Area NameRelevance Score
Security for Costs95
Costs80
Civil Practice75
International Commercial Law40
Arbitration30

16. Subjects

  • Civil Procedure
  • Security for Costs
  • Cryptocurrency Trading