further payments to be paid every 30 days. The policy further
provided that any action under the policy must be commenced
within one year of when “the cause of action” arose. The court found
that the insured’s cause of action crystallized 31 days after he made
his claim and then stated, “If he was entitled to those benefits, his
right to sue for them accrued every 30 days thereafter”: Wilson’s
Truck Lines, at p. 143 O.R. No explanation was given regarding why
a rolling limitation period would apply in the circumstances.
 Another instructive non-business interruption case from
this court is Bonilla v. Preszler (2016), 134 O.R. (3d) 478, 
O.J. No. 5315, 2016 ONCA 759. There, the trial judge granted
summary judgment and dismissed the appellant’s action against
the respondent insurer for terminating the income replacement
benefits (“IRB”) she had been receiving. On appeal, the insured
argued that her claim was subject to a rolling limitation period.
This court rejected that argument, finding that, “It is well
established in this court’s case law that the limitation period is
triggered by a single event, which is the refusal of an insurer to
pay the IRB claimed”: Bonilla, at para. 10.
 This court most recently considered the availability of rolling limitation periods in the context of an alleged breach of a lease
of commercial property. In Pickering Square Inc. v. Trillium
College Inc.,  O.J. No. 1118, 2016 ONCA 179, 347 O.A.C.
124, the defendant tenant paid rent as required but failed to
operate a business continually on the leased premises as it was
obligated to do under the lease. The court found that this was
a continuing breach because the plaintiff chose to affirm the lease
and, as a result, the parties were required to perform their obligations under it as they fell due: Pickering Square, at paras. 30-34.
 None of the cases cited above are on all fours with the case
at bar. The cases relied on by the appellants are closer factually to
the present case, but they are not binding and are largely devoid
of analysis. It is necessary therefore to consider first principles to
determine whether this is one of those instances where the court
should recognize a rolling limitation period.
 The jurisprudence suggests that a rolling limitation period
may apply in a breach-of-contract case in circumstances where the
defendant has a recurring contractual obligation. The question is
not whether the plaintiff is continuing to suffer a loss or damage,
but whether the defendant has engaged in another breach of contract beyond the original breach by failing to comply with an
ongoing obligation. In cases where there have been multiple
breaches of ongoing obligations, it is equitable to impose a rolling