Corp.,  O.J. No. 4610, 2017 ONCA 693, at para. 9;
Stojanovic v. Bulut,  O.J. No. 840, 2011 ONSC 874
(Master), at para. 5.
 As per Zeitoun, at paras. 49-50, if the Ecuadorian plaintiffs demonstrate impecuniosity on a balance of probabilities,
they can resist the motion by showing that their claim is not
plainly devoid of merit — a low evidentiary threshold. Conversely, where impecuniosity is not shown, a closer scrutiny of
the merits is called for and it will be legitimate to require the
Ecuadorian plaintiffs to demonstrate a good chance of success
on the main appeal in order to resist the motion. The Ecuadorian plaintiffs submit that test is satisfied given the merits of
their pending appeal.
 The Ecuadorian plaintiffs also advance a novel submission, one that Mr. Lenczner, their counsel, says should become
part of the law pertaining to security for costs. The Ecuadorian
plaintiffs submit that this motion should be approached differently because of the combination of two factors — it is part of an
action for recognition and enforcement of a foreign judgment,
and the original Ecuadorian action essentially amounts to a
class action. In oral argument, Mr. Lenczner suggested that
security for costs should never be ordered against an appellant
in such circumstances.
 Chevron and Chevron Canada submit that security for
costs is warranted because the Ecuadorian plaintiffs have not
provided evidence of impecuniosity, and have not established a
good chance of success in the pending appeal. They also reject
the appellant’s proposed new approach to the law of security for
costs, contending that the principle of comity does not require
the Ecuadorian plaintiffs to be treated more favourably than
 I have structured my analysis of the parties’ submissions
in two parts. I begin by outlining why security for costs should
be ordered under the usual analysis. I then explain why the
appellants’ proposed change to the law of security for costs does
not warrant a different conclusion.
 A party who seeks to establish impecuniosity must lead
evidence of “robust particularity”, with full and frank disclosure,
and supporting documentation as to income, expenses and liability: T.S. v. Publishing Group Inc. v. Shokar,  O.J. No.
1506, 2013 ONSC 1755 (Master); Mapara v. Canada (Attorney
General),  F.C.J. No. 1366, 2016 FCA 305, at para. 8.
Doherty J. (as he was then) explained the rationale for this