A sham transaction was defined in Snook v London & West Riding Investments [1967] 2 QB at 801 per Diplock LJ as, "acts done or documents executed by the parties to the "sham" which are intended by them to give to third parties or to the court the appearance of creating between the parties legal rights and obligations different from the actual legal rights and obligations (if any) which the parties intend to create." A "true sale opinion" if issued to legitimize a sham transaction may itself be a sham, and should therefore enliven the same penalties for the issuer as that of Lehman Brothers who relied on the true sale opinion to deceive the market into believing that their balance sheet was better than it was.