Looks at the phenomenon of the 'phoenix syndrome' where a limited liability company is put into liquidation to avoid its debts and then, almost immediately after, a new company is formed in the same business. It then continues trading in the same vein as the old. In "Archer Structures Ltd v Griffiths" ([2003] EWHC 957 (Ch), upreported) whilst one company was being wound up, an identical company was started with only a slight change of name by Mr Griffiths (G). A year later, Archer Structures (A) began a claim against the phoenix firm for unpaid debts. A won but G did not pay and the second company was also wound up. A claimed G was in breach of the Insolvency Act 1986, claiming M P J Contractors Ltd was a similar name to M P J Construction Ltd. G argued the two company names were not similar, which was rejected. G was ruled personally liable for the company debts. View judgment at www.bailii.org.