If he was using that word as a synonym for facade or device, it adds nothing. But otherwise we do not understand how Alamed could accurately be described as a “sham”. It was a genuine company, genuinely incorporated, with a genuine separate legal personality of its own: see in this context, the observations in the judgment of this court in Neu- feld v Secretary of State for Business, Enterprise and Regulatory Reform[2009] 3 All ER 790, at para 34