A dispute must first have crystallized. There is no formal requirement as to what constitutes a dispute, but clearly the general principles of a claim must have been made and refuted or at the very least, made and ignored. As in Cantillon Ltd v Urvasco Ltd [2008] EWHC 282 (TCC) and PT Building Services Ltd v ROK Build Ltd [2008] EWHC 3434 (TCC) but see also Enterprise Managed Services Ltd v McFadden Utilities Ltd [2009] EWHC 3222 (TCC).