"As hostile state actors increasingly make use of non-traditional methods to obtain sensitive information in Canada or abroad, contrary to Canada's interests, the court's appreciation of what constitutes 'espionage' must evolve," he wrote in his December 22 decision, made public this week.

"The officer further noted that Mr. Li has a strong interest in microfluidics [...] and that he indicated in his study plans that he wanted to dedicate his career to improving China's underdevelopment of the application of advances to point-of-care technology in the field of public health," says the Federal Court decision.