The oil and gas and mining industries developed the practice of creating royalties that would run with the land. This led to the Supreme Court of Canada’s decision in Bank of Montreal v. Dynex Petroleum Ltd. Despite the decision in Dynex recognizing a new property right and changing the common law, the law remained unsettled until the Third Eye Capital Corporation v. Ressources Dianor Inc./Dianor Resources Inc. and Manitok Energy Inc (Re) decisions apparently simplified the concept of royalties as property interests. In this article, the authors explore the overriding royalty, its common law evolution, the uncertainties surrounding its proper legal characterization, the implications of such legal uncertainty, and the shift the Dianor and Manitok decisions represent, while considering the nature of the interests that royalties represent, the manner in which industry has attempted to protect those interests, and the efficacy of such attempts.

Since the 1990s, electronic glossary systems have been a popular topic of inquiry for language educators and instructional designers. However, no published research describes a fully replicable toolset for performing empirical glossary user research in applied educational settings, leaving scant evidence about the effects of different styles of glossaries on reading comprehension and other outcomes (Welker, 2010). This study asked if learners would access vocabulary annotation features when offered in an electronic reading system, and if different modes of presentation would affect reading comprehension, according to the spatial contiguity principle (Mayer, 2005). Using offthe-shelf materials adapted for use with the system, students in an English for Academic Purposes (EAP) program (n = 20) at an American university read a short passage with an integrated glossary mechanism, followed by a reading comprehension assessment.