The earliest one that raised the issue was Bingham, above. The Court of First Instance has not explicitly established that the notification of the formal notice begins with an extrajudicial attachment, but it is apparent from its calculation of the time limits that it concerned the formal notice when determining the commencement.  Even if a note has been accelerated, if the due date has expired, or if a claim has been made on a requirement note, the limitation period due to the “toll” may actually be longer than the limitation period provided for in the Washington Treaty. Tolling acts as “Time Out”, where the clock stops ticking. On the other hand, in a dispute, this “discovery phase” can be costly, frustrating and time-consuming. .