See Danyluk v. Ainsworth Technologies Inc., 2001 SCC 44 at para 54 definition of "material fact". "A cause of action has traditionally been defined as comprising every fact which it would be necessary for the plaintiff to prove, if disputed, in order to support his or her right to the judgment of the court:  Poucher v. Wilkins (1915), 33 O.L.R. 125 (C.A.).  Establishing each such fact (sometimes referred to as material facts) constitutes a precondition to success."