Bureau, because they are civil remedies intended to "encourage compliance with the Competition Act, and failure to pay one may be enforced civilly as a debt due to the Crown. A fine, by contrast, is a punishment imposed by a court upon conviction of a criminal offence.... " That much is true, but other points of similarity and difference are more important. The potential civil remedy, the AMP, is enormous: $10-million on a first occurrence and $15-million for subsequent occurrences. Such penalties have been sought for Rogers Communications Inc., and now BCE Inc., over their allegedly deceptive advertising practices, not abuse of dominance, but the legal issue is the same in the end. The penalties are not recoveries of damages of the sort that private plaintiffs seek in ordinary civil proceedings, or recoveries for consumers. They look and feel a lot like criminal fines, and in fact are much larger than fines typically seen in criminal matters. Now, Parliament can set whatever penalties it sees fit. However, the Supreme Court has said that if a proceeding has a "true penal consequence," which explicitly includes a large fine, then it brings with it the legal protections of Section 11 of the Charter of Rights and Freedoms. Section 11 guarantees, among other things, a presumption of innocence, which presumption can be overturned only if a court or proceeding finds otherwise, beyond a reasonable doubt. Under the civil proceeding that the commissioner has pursued in the cases of Rogers and Bell, on the