82 Secondly, I want to say something further about the quantum of costs referred to in WMC's submission. According to the exhibit to the affidavit of Anthony Brooke Watson, a partner in the firm of solicitors acting for the plaintiff, sworn on 5 April 2012, the actual costs incurred by WMC in the 2000 proceeding as at 30 July 2004 was $1,018,359. Part of these costs were incurred before Steuler was a party to the 2000 proceeding and were therefore never recoverable from Steuler. The earliest total for WMC's costs was $893,185 as at 30 January 2004, roughly two years after Steuler had been joined. The proceeding had commenced some eighteen months earlier. Assuming that these costs had been incurred approximately evenly throughout this three and a half year period, only four-sevenths related to Steuler's time as a defendant. Thus, even if Steuler was liable for all costs thereafter, even though Protec remained as a defendant for more than two years, some $383,000 (three-sevenths of $893,185) at least, has to be deducted from WMC's costs figures. This would reduce WMC's relevant actual costs as at 30 July 2004 to about $635,000. However, WMC's party and party costs would be even less, generally somewhere between one-half and three-quarters of the actual costs. A common rule of thumb is two-thirds of the actual costs, or about $424,000 in this case as at 30 July 2004. This is not to say, however, that a party cannot take into account its actual costs when considering whether or not to accept an offer.