“…ions against persons unknown, Ineos Upstream Ltd v Persons Unknown(“Ineos”) [2019] EWCA Civ 515; [2019] 4 WLR 100 and Canada Goose Retail Ltd v Persons Unknown [2020] EWCA Civ 202; [2020] 1 WLR 2802. He summarised the combined effect of those cases as being:…”