R. v. Karimi, 2014 ONCA 320:
 The appellant submits that, as a matter of law, a threat to call the police, standing alone, can never constitute extortion.
 Again we disagree. As this court pointed out in R. v. H.A.,  O.J. No. 3777, the context must be considered in determining whether an otherwise apparently lawful threat (i.e., to call police) constitutes an extortive threat. A threat to call the police unless the complainants gave the appellant money could amount to extortion if the jury was satisfied the appellant knew the complainants had not stolen from him or did not reasonably believe they had stolen money from him. The charge did not suggest that a mere threat to call police would alone be sufficient to constitute extortion.